“The Supreme Court recently ruled that the fraud provision of section 523(a)(2)(A) does not require an explicit misrepresentation, but may arise from circumstances designed by a debtor to deceive a creditor and that are connected to the resulting debt. Husky Int’l Elecs., Inc. v. Ritz, 136 S. Ct. 1581, 1590, 194 L. Ed. 2d 655, 666 (U.S. 2016).” Case No. 17-22480-EPK.

    Add a header to begin generating the table of contents