The following excerpt is from Merritt v. Derham-Burk (In re Merritt), BAP No. NC-20-1026-TFB (B.A.P. 9th Cir. 2020):
"Cause" includes "unreasonable delay by the debtor that is prejudicial to creditors." 1307(c)(1). In that regard, "[a] debtor's unjustified failure to expeditiously accomplish any task required either to propose or to confirm a chapter 13 plan may constitute [the required causation] under 1307(c)(1)." Ellsworth v. Lifescape Med. Assocs., P.C. (In re Ellsworth), 455 B.R. 904, 915 (9th Cir. BAP 2011). The bankruptcy court found cause existed due to both unreasonable delay that is prejudicial to creditors and bad faith.10 We see no abuse of discretion in its finding that dismissal was appropriate.
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