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Expert Analysis

11th Circ. Equitable Tolling Ruling Deepens Circuit Split

By Paul Avron ( September 22, 2025, 2:22 PM EDT) -- In TL90108 LLC v. Ford, the U.S. Court of Appeals for the Eleventh Circuit held that its 1988 precedent, In re: Alton, establishing that equitable tolling was unavailable to extend Rule 4007(c)'s deadline to file a complaint objecting to discharge of debt, remained intact despite the U.S. Supreme Court's 2004 holding in Kontrick v. Ryan.[1]...

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