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Chapter 7In re Marrama, 549 U.S. 365, 127 S.Ct. 1105 (2007)
Debtor forfeited his right to convert his case to chapter 13 where he did not qualify as a debtor because of his bad faith concealment of assets In re AFI Holding, Inc., 355 B.R. 139 (9th Cir. BAP 2006), aff’d and remanded, 530 F.3d 832 (9th Cir. 2008)(for determination of removed trustee’s right to fees). Chapter 7 trustee had a material conflict of interest and thus was not disinterested as required by § 701(a)(1) where she previously represented insiders of the debtor. Totality of circumstances test applied. Failure to disclose all connections and appearance of inpropriety also supported her removal from the case. In re Concannon, 338 B.R. 90 (9th Cir. BAP 2006) Section 506(d) cannot be used by a chapter 7 debtor to strip off a wholly unsecured nonconsensual lien. In re Padilla, 222 F.3d 1184 (9th Cir. 2000) 1. Bad faith as a general proposition does not provide “cause” to dismiss a Chapter 7 petition under § 707(a). 2. Credit card “bust out” did not constitute cause under § 707(a). In re Laskin, 222 B.R. 872 (9th Cir. B.A.P. 1998) Ch. 7 debtors may not “strip off” unsecured second deed of trust on residence. In re Oxborrow, 913 F.2d 751 (9th Cir. 1990) - § 702 Election of trustee invalid where less then 70% of creditors requested election. |

