of pro se motions under section 144. For example, some courts have held that a pro se party cannot file a motion for disqualification under section 144 as they cannot comply with the statute’s explicit certification requirement. See, e.g., Buckenberger v. Reed-District, Civ. Action No. 6-7393, 2010 WL 3523021, at *1 (E.D.La. Aug. 31, 2010) (concluding “that a pro se litigant may not use 28 U.S.C. § 144 as a means to seek recusal because of the certification requirement” and therefore denying the motion). Other courts have concluded that a pro se litigant may file a motion under this provision so long as the party provides a certificate of good faith signed by a member of the bar, albeit not counsel of record. See, e.g., United States v. Rankin, 1 F.Supp.2d 445, 450 (E.D.Pa.1998) (<HOLDING>). Still other courts have determined that it is
holding that section 144 requires both a factual affidavit and a separate certificate that the affidavit was made in good faith holding that while the creditor has the initial burden to produce some evidence of lack of good faith the ultimate burden is on the debtor to prove his good faith holding that the excusable neglect inquiry is at bottom an equitable one that should be made by considering the danger of prejudice to the nonmoving party the length of the delay and its potential impact upon judicial proceedings the reason for the delay including whether it was in the reasonable control of the movant and whether the movant acted in good faith  holding that the defendant did not establish good faith as a matter of law holding that  144 requires that in the case of a pro se movant the certificate of good faith that accompanies the  144 affidavit be signed by any member of the bar of the court