are estimates, and are unlikely to be precise to the penny. However, the figures represent the Debtor's best estimates, and are made under penalty of perjury. The Court finds that it is entitled to rely upon them. 3 . See Docket No. 17. 4 . This Court requires parties to use a reaffirmation agreement which requires counsel to advise the Court that "[a] presumption of undue hardship has been established with re spect to this agreement. In my opinion, however, the debtor is able to make the required payment.” In this case, counsel for Debtor made no such representation in the Reaffirmation. At the hearing on approval of the Reaffirmation, counsel for the Debtor suggested that this was an oversight on her part. 5 . § 524(m)(l). 6 . See In re Laynas, 345 B.R. 505, 514 (Bankr.E.D.Pa.2006) (<HOLDING>). 7 . 338 B.R. 899, 904 (Bankr.D.N.M.2006). 8 .
holding that a debtors  522d1 exemption was invalid when the debtor exempted proceeds from the prepetition sale of the debtors marital home which were paid to a judgment creditor with an attachment on the debtors interest in the home holding that a debtors ability to make reduced payments under the icrp is relevant to the inquiry of whether the debtors reasonable future financial resources will cover payment of the debt while still allowing a minimal standard of living holding that where an action is brought by the debtors at the initial proceeding the appeal of that action is not a continuing proceeding against the debtors holding that payments made by third parties on behalf of debtors are disbursements notwithstanding the debtors lack of control over the funds holding that congress also provided for an additional layer of debtor protection under  524ml  by mandating judicial review of the reaffirmation agreements where the amount of the scheduled payments due on the reaffirmed debt as disclosed in the debtors statement exceeds the debtors available income citations omitted