The following excerpt is from Green v. Howard Family Trust Dated August 21, 1998 (In re Green), BAP No. NV-15-1349-KiLDo, BAP No. NV-15-1360-KiLDo (Related appeals) (B.A.P. 9th Cir. 2016):
If the bankruptcy court does specifically find and identify such "unusual circumstances," the debtor must also prove (1) there is a reasonable likelihood of plan confirmation within a reasonable time, (2) that the "cause" shown for conversion or dismissal was reasonably justified, and (3) that the cause for conversion or dismissal can be "cured" within a reasonable time. Warren v. Young (In re Warren), 2015 WL 3407244, at *4 (9th Cir. BAP May 14, 2015) (citing 1112(b)(2)(A) & (B)).
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