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ROSELLE v BERGER & MONTAGUE, P.C.

Summarizing by Bradley Pearce

IN RE: PAIGE

Case Type:
Consumer
Case Status:
Affirmed
Citation:
No. 18-1124 (3rd Circuit, Sep 27,2018) Not Published
Tag(s):
Ruling:
The Third Circuit Court of Appeals affirmed the Bankruptcy Court’s rulings, finding that the arguments by the pro-se debtors, Christopher Howard Paige and Michele Anna Paige, were “wholly without merit”. The Court further commented on the strikingly “inappropriate” and “indecorous” tone and nature of the debtors-appellants’ briefs.
Procedural context:
The Bankruptcy Court denied the debtors’ motions for sanctions. Debtors appealed, and the District Court affirmed. Subsequently, the debtors’ appealed the District Court’s ruling on their sanctions motions as well as the Bankruptcy Court’s refusal to admit two exhibits into evidence during the sanctions hearing. The Third Circuit reviewed the aforesaid rulings for an abuse of discretion and ultimately affirmed.
Facts:
After a 10-day trial, the Bankruptcy Court granted the pro-se debtors’ motion for judgment on all counts but subsequently denied the debtors’ five separate motions for sanctions. Debtors appealed, and the District Court affirmed. Thereafter, debtors appealed the District Court’s ruling on their sanctions motions as well as the Bankruptcy Court’s refusal to admit two exhibits into evidence during the sanctions hearing. The Third Circuit reviewed the aforesaid rulings for an abuse of discretion and ultimately: (1) affirmed the Bankruptcy Court’s rulings; (2) found that the debtors’ arguments were “wholly without merit”; (3) and, emphasized the importance of “proper decorum” and "professionalism" for all advocates that appear before the Court.
Judge(s):
Jordan, Vanaskie, and Nygaard, Circuit Judges

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