Young v. US Department of Education et al

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IN THE UNITED STATES BANKRUPTCY COURT
FOR THE NORTHERN DISTRICT OF OHIO
WESTERN DIVISION
In Re:
Kershauna C. Young,
Debtor,
_________________________________
Kershauna C. Young,
Plaintiff,
v.
U.S. Department of Education,
Defendant.
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Case No. 3:24bk31994
Chapter 7
Adversary Proceeding No. 3:25-ap-03015
Judge John P. Gustafson
CONSENT JUDGMENT
Plaintiff, Kershauna C. Young (“Plaintiff”), and the United States Department of
Education (“Education” or “Federal Defendant”) (collectively the “Parties”), by their
undersigned attorneys, agree as follows in this Consent Judgment:
The court incorporates by reference in this paragraph and adopts as the findings and orders
of this court the document set forth below. This document has been entered electronically in
the record of the United States Bankruptcy Court for the Northern District of Ohio.
Dated: April 27 2026
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1. WHEREAS, on October 16, 2024, Plaintiff filed a voluntary petition in the United States
Bankruptcy Court for the Northern District of Ohio for relief under Chapter 7 of the Bankruptcy
Code; and
2. WHEREAS, on January 16, 2025, the Court issued an Order of Discharge under 11
U.S.C. § 727 in Plaintiff’s Bankruptcy Case; and
3. WHEREAS, on March 25, 2025, Plaintiff filed a complaint (“Complaint”) in the instant
case to determine the dischargeability of federal student loans issued to her and held by Federal
Defendant under loan programs authorized under Title IV of the Higher Education Act of 1965, as
amended, (Doc. 1); and
4. WHEREAS, on May 22, 2025, Federal Defendant filed an answer (“Answer”), (Doc. 11);
and
5. WHEREAS, the Complaint seeks discharge of Plaintiff’s federal student loans pursuant
to 11 U.S.C. § 523(a)(8), because repayment would impose an undue hardship; and
6. WHEREAS, Plaintiff submitted to ED an Attestation in Support of Request for
Stipulation Conceding Dischargeability of Student Loans (“Attestation”); and
7. WHEREAS, only federal student loan debt incurred by Plaintiff prior to Plaintiff’s
bankruptcy petition date is potentially eligible for a hardship discharge; and
8. WHEREAS, Plaintiff’s federal student loan amounts in this document are based on
valuations on approximately April 25, 2025, but current amounts, which may differ due to
accruing interest or other factors, will be used for calculating any discharge; and
9. WHEREAS, pursuant to the table, below, Plaintiff has prepetition federal student loan
debt, including interest, of approximately $89,428.31 (“Plaintiff’s Federal Student Loan Debt”),
corresponding to prepetition federal student loans issued to Plaintiff (“Plaintiff’s Federal Student
Loans”):
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Plaintiff’s Prepetition Federal Student Loan Debt
Considered for Discharge as of 4/25/2025
Loan # Loan Date Original
Loan
Amount
Date
Entered
Repymt
Updated
Principal
Updated
Interest
Total Due
(as of
4/25/25)
13 $41,450.00 $9,109.00 6/15/14 $8,149.70 $3,230.69 $11,380.39
12 $41,450.00 $5,500.00 6/15/14 $3,904.91 $541.22 $4,446.13
11 $41,169.00 $7,000.00 6/15/14 $8,511.70 $3,374.25 $11,885.95
10 $41,169.00 $5,500.00 6/15/14 $5,858.28 $811.92 $6,670.20
9 $40,886.00 $6,000.00 6/15/14 $7,780.84 $3,077.52 $10,858.36
8 $40,798.00 $4,500.00 6/15/14 $4,735.15 $654.93 $5,390.08
7 $40,498.00 $4,000.00 6/15/14 $5,459.07 $2,159.44 $7,618.51
6 $40,498.00 $3,500.00 6/15/14 $3,738.40 $683.13 $4,421.53
5 $40,498.00 $2,000.00 6/15/14 $2,729.50 $1,079.60 $3,809.10
4 $39,946.00 $6,000.00 6/15/14 $9,646.46 $2,629.33 $12,275.79
3 $39,946.00 $3,500.00 6/15/14 $3,775.55 $858.54 $4,634.09
2 $39,716.00 $3,500.00 6/15/14 $2,567.04 $621.33 $3,188.37
1 $39,716.00 $2,000.00 6/15/14 $2,044.18 $805.63 $2,849.81
Totals $0.00 $0.00 0 $68,900.78 $20,527.53 $89,428.31
and
10. WHEREAS, ED agrees that Plaintiff’s Federal Student Loan Debt and Plaintiff’s
Federal Student Loans should be discharged under 11 U.S.C. § 523(a)(8) based on the
Attestation, information obtained during discovery, and current U.S. Department of Justice and
ED guidelines, including the November 17, 2022, Guidance for Department Attorneys Regarding
Student Loan Bankruptcy Litigation; and
11. WHEREAS, ED agrees that any accrued interest on Plaintiff’s Federal Student Loan
Debt should be likewise discharged; and
12. WHEREAS, the Parties desire to amicably resolve the matters at issue in the Adversary
Proceeding and, therefore, have agreed to enter into this Consent Judgment; and
13. WHEREAS, each party agrees to bear their own fees and costs of this litigation; and
14. WHEREAS, this adversary proceeding shall be closed as all issues are settled or rendered
moot; and
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15. WHEREAS,jurisdiction of this case is retained to enforcy this Judgment, induding
en:tering. further orders that are necessary tQ interpret and enforce this Judgment; it is
16. ORI>ERED AND ADJUDGED, that, pursuant to 11 U.S.C. § 523(a)(8), based upon
consideration of the Complaint, the_ stipulations contained herein, applicable guidance, and consent
ofthe·Parties, Plaintiffs Federal ~tudent Loan Debt, plus accrued interest, of approximately
$89,428.31, corresponding to the full balance of Plaintiffs Federal Student Loans (Loans 1-13),
above, is hereby DISCHARGED. •I
Respe~tfully submitted,
David M. Toepfer
United States Attorney
Guillermo J. Rojas (#00698820)
Assistant United States Attorney •
Four Seagate, Suite 308
Toledo, OH43604-2624 •
-P~(41-9)-259-6376i F, {419} 2-59-6471
Guillermo.Raj as@usdoj.gov
Attorney for United States Department	• 	I
of Education
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/x.J?, 	j£luA 	;_ .l~l?
Patti Baumgartner-Novak:
612 S Main Street Heck Bldg #104
Findlay, OH 45840
Phone: (419) 427-2406
PMBN@Buckeye-Express.com
Attorney for Plaintiff, Kershauna C. Young
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