Student Loan Adversary Filing – Cesar Medina and Krystal Anne Medina – Adversary Proceeding

The following student loan bankruptcy adversary case filing is presented here to help others dealing with the same issues.

Case Location: United States Bankruptcy Court, S.D. California

Summary of Document Filed:

Amended Memorandum of Points and Authorities filed by Christopher R. Bush of Christopher R. Bush on behalf of Krystal Anne Medina. (Attachments: # 1 Declaration) (related documents 47 Memorandum of Points and Authorities) (Bush, Christopher) (Entered: 04/29/2020) 29 April 2020 Attachment Case 19-90065-LT Filed 04/29/20 Entered 04/29/20 12:00:57 Doc 50-1 Pg. 1 of 9 1 Austin Smith 2 (NY Bar No. 5377254)(Pro Hac Vice) Smith Law Group LLP 3 3 Mitchell Place 4 New York, NY 10017 917-992-2121 5 [email protected] 6 7 Christopher R. Bush CASB 243471 Law Office of Chris Bush 8 2727 Camino del Rio S., Ste 135 9 San Diego, CA 92108 619-678-1134 10 [email protected] 11 12 UNITED STATES BANKRUPTCY COURT 13 SOUTHERN DISTRICT OF CALIFORNIA 14 IN RE: ) Case No. 17-05276-LT 15 CESAR MEDINA ) Chapter 7 KRYSTAL ANNE MEDINA ) 16 ) 17 ) ) 18 19 20 KRYSTAL ANNE MEDINA ) Adversary No. 19-90065-LT 21 Plaintiff, ) 22 vs. ) NATIONAL COLLEGIATE STUDENT ) 23 LOAN TRUST 2006-3; ) 24 ) 25 ) ) 26 ) 27 ) DECLARATION OF PROFESSOR JOHN BROOKS II 28 1 Case 19-90065-LT Filed 04/29/20 Entered 04/29/20 12:00:57 Doc 50-1 Pg. 2 of 9 1 I, John R. Brooks II, mindful of the penalties of perjury, do declare and state: 2 1. I am over the age of 18 years and competent to make this declaration. I make 3 this declaration based on my own personal knowledge and without drawing 4 upon any specialized methods or processes. 5 1. I am a full-time, tenured Professor of Law at Georgetown University Law 6 Center, in Washington, D.C. My primary fields of expertise are federal tax 7 law and federal student loan law. I teach courses on federal income tax law, 8 corporate tax law, and tax policy. I have published academic research on 9 both tax law and student loan law in law journals including the Tax Law 10 Review, the Georgetown Law Journal, the Utah Law Review, the Journal of 11 Legal Education, and Tax Notes. I have also published op-eds on student 12 loans in the New York Times and the L.A. Times. I have been quoted by or 13 interviewed for stories related to tax or student loans in outlets such as 14 National Public Radio, USA Today, Politico, Inside Higher Ed, Newsweek, 15 Buzzfeed, Marketplace, and more. I have consulted on both tax and student 16 loan legislation with Congressional offices and have aided in drafting 17 pending legislation related to student loans. 18 2. Prior to teaching, I was a tax attorney for Ropes & Gray LLP and a judicial 19 clerk for Judge Norman H. Stahl on the U.S. Court of Appeals for the First 20 Circuit. 21 3. I have been compensated by Plaintiff’s counsel for my time spent at my 22 average hourly rate of $500 but I understand that Plaintiff’s counsel has 23 agreed to cover this sum personally and Ms. Medina has not been charged in 24 any way …

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