The following excerpt is from In re Alvarado, 496 B.R. 200 (E.D. Cal. 2013):
11 U.S.C. 707(a)(1)-(3). The types of conduct enumerated in 707(a) as cause are not exclusive. Neary v. Padilla (In re Padilla), 222 F.3d 1184, 1191 (9th Cir.2000), partially superseded by statute on other grounds,11 U.S.C. 707(b)(3)(A).
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