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Mann v. Chase Manhattan Mortgage Corp.

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In this January, 2003 decision from the 1st Circuit Court of Appeals, the Court considers the debtors' contention that the lender's mere recordation of postpetition, preconfirmation attorney fees incurred by the lender, on its internal books, violated the automatic stay. The Court disagreed, saying such unilateral accruals of amounts assertedly due, but in no manner communicated to the debtor, the debtor's other creditors, the bankruptcy court, nor any third party, plainly are not the sort of "act" Congress sought to proscribe.


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