S.Ct. 3214, 96 L.Ed.2d 701 (1987), it is hard to see anything problematic in the acceptance of payment when the request has been honored. The protections of § 524(c), the court’s contempt power, and the debtor’s privilege of rescinding the agreement all afford protection against exploitation, and we are aware of no caselaw squarely holding that voluntary payments may never be accepted during the stay. 2. Mischaracterization of the Law The Pertusos maintain that the reaffirmation letter was misleading because it represented that Ford could seize the van if the plaintiffs did not sign the agreement. The Pertusos acknowledge that a circuit split exists on this issue. Compare In re Parker, 139 F.3d 668, 672-73 (9th Cir.), cert. denied, 525 U.S. 1041, 119 S.Ct. 592, 142 L.Ed.2d 535 (1998) (<HOLDING>) with In re Burr, 160 F.3d 843, 848-49 (1st
holding that so long as a complaint provides notice plaintiff can recover under any theory supported by the evidence holding that administrative decisions are subject to reconsideration as long as the agency still retains control of the proceeding holding that that choices as to selection and arrangement are entitled to copyright protection only so long as they are made independently holding that debtor can retain collateral without reaffirmation as long as required payments are continued holding that a sentence is proper as long as it is within the statutory range prescribed for the offense without regard to drug quantity