In re Graves, 464 B.R. 225 (Bankr. E.D. Pa. 2012)

(bankruptcy trustee objected to Chapter 13 debtors’ exemption of debtor wife’s settlement proceeds received for pre-petition loss of consortium claim arising out of automobile accident involving debtor husband; court holds that generally an 11 U.S.C § 522(d)(11)(D) exemption is applicable to a loss of consortium claim; in this case, there was no evidence that the settlement proceeds were paid in settlement of the wife’s claim, so the interest in her claim remains unliquidated and a decision regarding the exemption would be premature).