
Bankruptcy Proofs of Claim Based on Time-Barred Debt
To say that there was a split among the circuits may be a bit of an oversell. In Crawford v. LVNV Funding, LLC, 758 F.3d 1254 (11th Cir. 2014), the 11th Circuit Court of Appeals held that a plaintiff stated a claim under the Fair Debt Collection Practices Act (“FDCPA”) where a creditor filed a bankruptcy