For the third time in less than two years, the Eleventh Circuit Court of Appeals has ruled that a chapter 7 debtor who does not reaffirm secured debt or redeem the property must surrender the property. In re Woide, No. 17-10776 (11th Cir. Apr. 5, 2018).
In Woide, the debtors filed a chapter 13 bankruptcy petition, and on schedule A, listed their real property and stated "to be surrendered." The case was later converted from chapter 13 to 7, and the debtors did not file any statement of intention with respect to the property. After the close of the debtors' bankruptcy case, the secured creditor ...
In Edelsberg v. Vroom, Inc., No. 16-cv-62734-GAYLES, 2018 WL 1509135 (S.D. Fla. Mar. 27, 2018), the Southern District of Florida held that an advertisement directing interested persons to contact a number provided in the advertisement constituted prior express consent under the Telephone Consumer Protection Act ("TCPA").
The plaintiff, Mark Edelsberg ("Plaintiff"), posted a classified advertisement for the sale of a vehicle on Craigslist. The advertisement included the price and information about the vehicle and stated "Call XXX-XXX-6445 for more info . . . do NOT contact me ...