The following excerpt is from Cooke v. Renshaw (In re Cooke), Adv. No. 13-01062-PC, BAP No. CC-15-1037-KiTaKu (B.A.P. 9th Cir. 2016):
10. Hultman relied on decisions, from other circuits, which stated this rule in a case decided under the Act. See 82 F.2d at 941 (citing Rutter v. General Motors Acceptance Corp., 70 F.2d 479, 481 (10th Cir. 1934); In re Ricther, 57 F.2d 159, 160 (2nd Cir. 1932); Bailey v. Ross, 53 F.2d 783, 784 (8th Cir. 1931)).
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