The debtors filed an application for a hardship discharge under 11 U.S.C. § 1328(b) and (c).  After confirmation of the debtors' Chapter 13 plan, the female debtor was diagnosed with a rare, chronic autoimmune neuromuscular disease which caused her to quit her job due to the resulting muscle weakness.  Under Section 1328(b), Chapter 13 debtors can obtain a discharge after confirmation even though complete payments under the plan have not been made, so long as the debtors show that the following three essential criteria are satisfied: (1) the failure to complete plan payments is due to circumstances for which the debtors cannot justly be held accountable; (2) the value of property distributed under the plan on account of each allowed unsecured claim is not less than the amount that would have been paid on such claim if the estate of the debtor had been liquidated under chapter 7 of this title on such date; and (3) modification of the plan is not practicable.  See 11 U.S.C. § 1328(b)(1)-(3).  The Court denied the debtors' application for a hardship discharge, holding that although the female debtor's illness was an unforeseeable economic circumstance, the debtors have failed to establish that they have made every effort to overcome their situation by failing to present evidence that would preclude the possibility of improvement in the female debtor’s health or the possibility of finding suitable alternative employment.

Claimant cannot seek relief from stay under section 362(b) or 362(d) to enforce portion of divorce decree obligating the debtor for all indebtedness associated with a vehicle because payment to the creditor on the vehicle was not a domestic support obligation as defined in section 101(14A) of the Bankruptcy Code.

Court denied, without prejudice to the filing of a supplemental application, the third interim application for compensation and reimbursement of expenses of the trustee's attorney. It is within Court's sound discretion to decline to award compensation until all relevant circumstances and factors affecting the determination of fair and reasonable compensation for the attorney are known.  Court also questioned the firm's entitlement to any compensation for litigation in light of the failure of the trustee to seek approval of the Court for the firm's retention to provide such services.

The Court held that additional paragraphs added by the debtor to Paragraph 11 of the Uniform Plan do not contain provisions peculiar to debtor's financial situation and instead are unnecessary and is likely, if applicable, to increase the costs of administration and litigation.  Further, if the language in Paragraph 11 is an inaccurate statement of law, it violates 11 U.S.C. § 1322(b)(11), which prohibits against including any provision that is not consistent with the Bankruptcy Code.  Therefore, the Court sustained the Chapter 13 trustee's objection to confirmation of debtor's plan and held that such additional paragraphs must be deleted from the Chapter 13 plan before confirmation or else they would require the Court to adjudicate matters that are not yet before it.