In re Turner-Williams (Case No. 13-51463) 2/4/2014
Court ruled that debtor who failed to complete credit counseling under Bankruptcy Code § 109(h) was not eligible to be a debtor. Without a showing of deferment or exigent circumstances, the Court could not authorize the debtor to file certification of completion after petitioning for bankruptcy protection, even if she filed the certificate only eight days after filing the petition.