by Tara Twomey on September 1, 2011 Bell v. Fitzgerald, No. 10-10870 (D. Mass) Type: Amicus Date: June 10, 2011 Description: Whether “property distribution” under section 1325(a) may be satisfied by issuance of new Note. Result: Affirmed. Debtor lost. Bell NACBA amicus Bell opinion July 2011