she “admitted that she was not permanently disabled and was capable of being gainfully employed”). To meet his burden of proof under the third prong, Marcotte has shown good faith efforts to repay his Loan by making payments for a significant period of time, continuing his payments until filing for chapter 7 relief and consolidating his Loan. Cf. Spence, 541 F.3d at 545 (stating that debtor did not make good faith efforts because she did not fully explore consolidating her student loans and filed for bankruptcy before making one payment); Mosko, 515 F.3d at 325 (finding that debtors’ payments on their student loans were insufficient to satisfy the third prong because they did not make payments when their income substantially exceeded their necessary expenses); Frushour, 433 F.3d at 402 (<HOLDING>). In addition, Marcotte has minimized his
holding debtor satisfied first prong even though she had cable television holding that debtor did not satisfy the third prong because she did not seek out loan consolidation options even though she made several payments on her student loan debt holding that the bankruptcy court lacked the power under  105a to grant the partial discharge of student loan debt when the debtor did not show undue hardship as required by statute holding admittedly in a heal loan context that congress did not intend to allow a debtor who spent decades not making loan payments even after working full time for several years to receive a discharge because his health begins to fail as he approaches retirement age holding that where parties to an oral loan agreed that the loan would be repaid on demand the statute of limitations did not begin to run until the date plaintiff demanded repayment of the loan