Summary:
A pro se debtor failed to obtain the pre-bankruptcy credit counseling required by 11 U.S.C. § 109(h) and the bankruptcy court sua sponte issued an Order to Show Cause why the case should not be dismissed. Despite opposition from the Chapter 7 trustee, who, having been alerted by Wells Fargo, believed there were non-exempt funds available, the bankruptcy court held that the case must be dismissed.