the debtor, thus effectuating the fresh start policy of the Code. These considerations, however, ‘are applicable only to honest debtors.’ ” In re Van Horne, 823 F.2d 1285, 1287 (8th Cir. 1987). In the Eighth Circuit, a creditor proceeding under § 523(a)(2)(A) must prove the following elements: (1) the debt- or made representations; (2) at the time made, the debtor knew them to be false; (3) the representations were made with the intention and purpose of deceiving the creditor; (4) the creditor justifiably relied on the representations; and, (5) the creditor sustained the alleged injury as a proximate result of the representations having been made. In re Ophaug, 827 F.2d 340, 342 n. 1 (8th Cir.1987), as modified by Field v. Mans, 516 U.S. 59, 74-75, 116 S.Ct. 437, 133 L.Ed.2d 351 (1995) (<HOLDING>). Plaintiff has satisfied the first three
holding that in fraud and nondisclosure claims a plaintiff must show actual and justifiable reliance holding standard under section 523a2a is justifiable reliance holding no justifiable reliance as a matter of law holding that  523a2a requires justifiable but not reasonable reliance holding that a creditors reliance under  523a2a need only be subjectively justified and not objectively reasonable