Marcelle E. West

IN THE UNITED STATES BANKRUPTCY COURT CLERK FOR THE WESTERN DISTRICT OF PENNSYLVANIA U.S. BANKRUPTCY COURT - WDPA In re: : Case No. 23-20618-CMB : MARCELLE E. WEST, : Chapter 13 : Debtor. : Related to Dkt. Nos. 7, 43 : Michael S. Geisler, Esq. Pittsbrugh, PA Attorney for the Debtor MEMORANDUM OPINION Although a creditor’s silence can imply consent in a chapter 13 case, consent does not relieve debtors from all affirmative evidentiary burdens imposed by the Bankruptcy Code.1 At issue is whether a lack of creditor opposition alone can amount to clear and convincing evidence that a case was…