the exemption in the first place because it was initially claimed fraudulently or in bad faith.” Woolner, 2014 WL 7184042, at *3. The Woolner analysis, however, remains a decidedly minority view. See, e.g., Baker, 791 F.3d at 682; In re Castellano, 550 B.R. 214, 216-17 (Bankr. E.D.N.Y. 2016) (finding that Siegel was dispositive in overruling exemption objection despite trustee’s reliance on Fed. R. Bankr. P. 4003(b)(2)); In re Liao, 553 B.R. 584, 602 n.3 (Bankr. S.D. Tex. 2016) (finding that since Woolner, no other court has followed its rationale and that even the Woolner court would not be able to apply it in future cases because of the Sixth Circuit’s subsequent precedent in Baker, 791 F.3d 677)); In re Coyle, No. 14-90026, 2016 WL 828459, at *3 n. 2 (Bankr. C.D. Ill. Mar. 2, 2016) (<HOLDING>). In fact, the United States Court of Appeals
holding that section 704 does not bar district court jurisdiction when the claims court does not provide a special and adequate review procedure for that claim holding a debtors claim for loss of consortium to be entitled to an exemption under the oklahoma exemption statute and collecting other bankruptcy decisions recognizing a debtor spouses loss of consortium as the basis for allowing an exemption under federal and various state exemption statutes holding that fraudulent oral misrepresentation of the level of benefits does not provide the basis for a nonpreempted claim even though erisa may also provide no remedy holding that a debtors technically incorrect exemption in a wrongful death claim based on west virginias homestead exemption stands as claimed because the trustee did not object to the exemption in time holding that fed r bankr p 4003b2 does not provide a substantive basis to deny a claim of exemption and stating that the court did not believe the reasoning of woolner was persuasive in any respect