755 (Bankr.M.D.Fla.2006) (concluding that § 522(p)’s exemption cap applies separately to each debtor in joint cases). 8 . Similarly, in Wallace v. Rogers (In re Rogers), we also passed on an opportunity to adopt either the title or equity interpretations of § 522(p)(l), finding that it was unnecessary to the resolution of the case before us at that time. 513 F.3d at 222-23. 9 . The bankruptcy court found that the Feh-mels made a down payment of $73,841.23. However, they took out a mortgage of $304,000 on the property, larger than was necessary to finance the rest of its purchase price of $375,000. Consequently, when the Fehmels took title to the Lampasas property, they only had equity in their property of $71,000, not $73,841.23. 10 . If the Fehmels acquired $278,01 162 (S.D.Ohio 1991) (<HOLDING>). In this case, the Fehmels’ decision to claim
holding that the burden of proof is on the claimant holding that objector cannot escape the burden of proof assigned to an objecting party under rule 4003c because the exemption claim relates to a settlement agreement which fails to allocate damages into specific categories of recovery holding that the trustee objector cannot escape the burden of proof assigned to an objecting party under rule 4003c because the exemption claim relates to a settlement agreement which fails to allocate damages into specif ic categories of recovery holding that the burden of proof is initially placed upon the objector with respect to any objections he files and  this burden does not shift to the debtor merely upon a showing that the debtor has failed to allocate the personal injury settlement into its various component parts holding that the debtor has the burden of showing that collateral estoppel applies