of the equity in their homestead actively, and such equity is capped at $273,750, then at the very least, $4,269.57 of the Fehmels’ exemption would be improperly claimed. 11 . For example, the Fehmels likely could have introduced evidence showing whether similar properties in Lampasas appreciated during the same period without any improvements. 12 . We note that this case bears some resemblance to the many cases where courts have reviewed debtors' exemption of the proceeds of settlement agreements from their bankruptcy estates. In such cases, courts have held that debtors do not have the initial burden of breaking down these awards into exempt proceeds for bodily injury and nonexempt proceeds for pain and suffering. See, e.g., In re Harrington, 306 B.R. 172, 183 (Bankr.E.D.Tex.2003) (<HOLDING>); Lester v. Storey (In re Lester), 141 B.R.
holding that a settlement agreement is not a court order and therefore a violation of the settlement agreement would not subject a party to contempt holding that the burden of proof is initially placed upon the objector with respect to any objections he files and  this burden does not shift to the debtor merely upon a showing that the debtor has failed to allocate the personal injury settlement into its various component parts holding that objector cannot escape the burden of proof assigned to an objecting party under rule 4003c because the exemption claim relates to a settlement agreement which fails to allocate damages into specific categories of recovery holding that rule 56c requires summary judgment against a party who fails to make a showing sufficient to establish the existence of an element essential to that partys ease and on which that party will bear the burden of proof at trial holding that an insurer lacked standing to raise the issue of the intent of the parties to the settlement agreement to which it was not a party