proceeds constitute a preferential transfer under § 547(b); however, Electric City contends that the proceeds fall under an exception to the preference rule which makes them unavoidable. Section 547(c)(8) of Title 11 makes a transfer unavoidable “if, in a case filed by an individual debtor whose debts are primarily consumer debts, the aggregate value of all property that constitutes or is affected by such transfer is less than $600.” 11 U.S.C. § 547(c)(8). Electric City argues that in determining whether a creditor has received $600 in value, a court must focus on each individual transfer. Because each of the individual transfers of Hailes’ garnished wages were less than $600, Electr ; In re Bunner, 145 B.R. 266, 267 (C.D.Ill.1992) (same) with In re Clark, 171 B.R. 563 (W.D.Ky.1994) (<HOLDING>); In re Howes, 165 B.R. 270 (E.D.Mo.1994)
holding that a fraudulent transfer of property by a coconspirator constituted a willful and malicious injury under section 523a6 because the debtor transferred property without just cause in an attempt to place it beyond the reach of a 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 holding that debtor cannot aggregate multiple transfers to a single creditor in ninetyday prefiling period to reach  547c8s 600 requirement recognizing need to balance interests of debt or and creditor in determining nature of protection to be afforded creditor