City maintains that each transfer is exempt from the preference rule under § 547(c)(8). Hailes argues that the transfer in this case was the writ of garnishment; therefore, the aggregate value of the transfer should be measured by the sum of all of the payments. Under Hailes’ theory, the aggregate value of the transfer exceeded $600, and § 547(e)(8) would not exempt the garnished proceeds from the preference rule. Therefore, the sole issue on appeal is whether, under § 547(c)(8), a court may aggregate all transfers to a single creditor to determine whether the creditor received $600 in value in the pre-filing period or whether each transfer must be evaluated individually. The issue has divided the few courts that have considered it. Compare In re Djerf, 188 B.R. 586, 588 (D.Minn.1995) (<HOLDING>); In re Alarcon, 186 B.R. 135 (D.N.M.1995)
recognizing need to balance interests of debt or and creditor in determining nature of protection to be afforded creditor holding that debtor can aggregate multiple transfers to a single creditor in ninetyday prefiling period to meet  547c8s 600 requirement holding that a bankruptcy court can order rejection retroactive to an earlier date to avoid penalizing the debtor for an unnecessary delay caused by the creditor holding that as a general rule  affirmative action by the creditor must be taken to make it known to the debtor that the creditor has exercised his option to accelerate holding that creditor did not have actual knowledge of the bankruptcy filing where the debtor informed creditor of the possibility that a bankruptcy case would be filed