necessary expenses); Brunner v. N.Y. State Higher Educ. Servs. Corp. (In re Brunner), 46 B.R. 752, 758 (S.D.N.Y.1985) (finding that debtor did not satisfy the third prong because she filed for discharge of the student loan within a month of the date the first payment came due). 20 . See Wallace v. Educ. Credit Mgmt. Corp. (In re Wallace), C/A No. 06-2735, 2010 WL 5764771 slip op. at *4 (Bankr.S.D.Ohio Dec. 1, 2010) (stating that several courts have defined "minimal standard of living” to include "vehicles to go to work, to go to stores, and to go to doctors ... [and] insurance for ... those vehicles.” (citing Ivory v. United States (In re Ivory), 269 B.R. 890, 899 (Bankr. N.D.Ala.2001))); see also Peña v. United Student Aid Funds, Inc. (In re Peña), 155 F.3d 1108, 1114 (9th Cir.1998) (<HOLDING>). 21 . In re Brown, Adv. No. 06-24, 2007 WL
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 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 debtors were entitled to discharge of their student loans despite the fact that they received a postpetition lump sum payment for pastdue disability and used it to purchase an approximately twenty 20 year old car and to pay other bills the ninth circuit reasoned that this did not preclude the debtors from satisfying the third brunner prong because of the cars age implying that debtors did not incur a large expense and the creditors failure to show why good faith would require the debtors to pay off the student loan instead of their other debts holding pursuant to bankruptcy rule 7004b9 that because the creditor mailed the complaint and summons to the debtors attorney and to the address listed in the debtors bankruptcy petition service of process was sufficient even if the debtors were out of the country and did not actually receive notice of the complaint and summons holding that a debtors right to strip off a wholly unsecured lien is conditioned on the debtors obtaining confirmation of and performing under a chapter 13 plan that meets all of the statutory requirements rather than on a debtors discharge