hard proof rather than spongy rhetoric.” Hale, 289 B.R. at 792 (citing Mesnick v. Gen. Elec. Co., 950 F.2d 816, 822 (1st Cir.1991)). B. Education Loans Under 11 U.S.C. § 528(a)(8) Although the purpose of the Bankruptcy Code is to guarantee honest debtors a “fresh start” through the bankruptcy discharge, Grogan v. Garner, 498 U.S. 279, 286-87, 111 S.Ct. 654, 112 L.Ed.2d 755 (1991), Congress legislated under § 523(a)(8) that “any educational benefit overpayment or loan made, insured or guaranteed by a governmental unit, or made under any program funded in whole or in part by a governmental unit or nonprofit institution” is excepted from discharge, unless the debtor can establish “undue hardship.” See 11 U.S.C. § 523(a)(8); see also In re Pelkowski, 990 F.2d 737, 739 (3rd Cir.l993)(<HOLDING>). Moreover, Congress has amended § 523(a)(8) a
holding that no waiver of immunity exists for damages arising out of alleged educational malpractice claim against a school board holding transfer of usda loans to private lenders did not extinguish a rural water districts indebted on those loans for purposes of  1926b holding that we may apply a presumption of reasonableness to a sentence within the guidelines range holding that a defendants goodfaith belief that he intended to repay the loans he procured through misrepresentation was not a defense to wire fraud holding that  523a8 may apply to nonstudent comakers of educational loans