Circuits have concluded that the plain meaning of section 521(2)(A) limits a debtor to specifying one of the three options enumerated in the provision if retention is “applicable.” The First Circuit, for instance, has reasoned that “it is perfectly conventional usage, and perfectly good English, for Congress to have phrased § 521(2)(A) in the way it did because it intended chapter 7 debtors to elect surrender or retention, and then, ‘if retention is ‘applicable,’ to specify which of the following three retention options they intend to employ.” Burr, 160 F.3d at 848 (citing Boodrow, 126 F.3d at 59 (Shadur, J., dissenting)); see also Taylor, 3 F.3d at 1516 (finding that plain language of section 521 provides a debtor with only three option to retain collateral); Johnson, 89 F.3d at 252 (<HOLDING>); Lowry, 882 F.2d at 1545 (“The plain English
holding when ordinance language is clear courts must give language its plain meaning holding that the clear language of section 5212 limits a debtor to the options enumerated in the provision holding that a provision of the constitution is to be construed in the sense in which it was understood by the framers and the people at the time of its adoption but that if new products or circumstances that did not exist at the time the constitutional provision was enacted fall within the meaning of the provision the constitutional provision applies to them holding that debtor failed to meet its burden of proving lease should be recharacterized as a disguised security agreement because the record before the court provides no credible evidence as to the projected fair market of the leased equipment on the dates the debtor will be entitled to exercise the purchase options holding defendants agreement to consentsearch provision not coerced merely because it was one of two undesirable options