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1 Any Attorney or Party

Any Street
2 Any Town, CA 55555

3 714-555-5555

4 Any Attorney or Party

8 UNITED STATES BANKRUPTCY COURT

9 ___________ DISTRICT OF ____________

10

11 IN RE: ________________, ) Case No.


)
12 Debtors, ) Chapter 7
)
13 Any Plaintiff ) Adv. Proc No.
)
14 Plaintiff, ) COMPLAINT TO DETERMINE NON-
) DISCHARGEABILITY OF DEBT UNDER
15 vs. ) SECTION 523A(a)(2) OF THE BANKRUPTCY
) CODE AND FOR DENIAL OF DISCHARGE
16 Any Defendant, ) UNDER SECTION 727(a)(4) OF THE
) BANKRUPTCY CODE
17 Defendant. )
)
18 ) (Hearing date to be set by summons)
)
19 )
)
20

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address. Be sure to remove this notice before using this document.
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26 COMPLAINT TO DETERMINE NON-DISCHARGEABILITY OF DEBT


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COMES NOW, _____________________Pro Se (“Plaintiff”), for his complaint
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COMPLAINT TO DETERMINE NON-DISCHARGEABILITY OF DEBT
1 against the Defendant, ______________ (“Defendant”), and alleges as follows:
2 1. This is a core proceeding over which this court has jurisdiction under Title 28
3
U.S.C. § 157(b).
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2. Defendant is the debtor in this chapter 7 case which was filed on __________,
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the Deadline to file a complaint for determination of dischargeability is _________, so this complaint

7 is timely. Plaintiff is a creditor of defendant by virtue of the following facts:

8 a. On or about ___________, Defendant published specific public solicitations


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on the internet, requesting loans for real estate projects that promised large, prompt returns on
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investments. Plaintiff inquired into Defendant’s solicitation, wherein Defendant formally offered
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Plaintiff an investment opportunity in the form of a loan that guaranteed a large, prompt return on his
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13 principal, plus interest.

14 b. On or about _____________, __________ and Plaintiff agreed to specific


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terms of a loan. _________________represented to Plaintiff that in exchange for
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_______________________ (__________), he would provide him with a repayment of that amount
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on or before ____________, plus ______________ ($_____________) in interest on the principal
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19 amount. The total amount agreed upon, which came due on _____________ was

20 ____________________________($__________________). The agreement was reduced to writing


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and signed by Plaintiff and ________on ______________ (hereinafter referred to as "Promissory
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Note").
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27 complaint-for-fraud-in-united-states-bankruptcy-court
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COMPLAINT TO DETERMINE NON-DISCHARGEABILITY OF DEBT

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