Adams v. Zelotes, et al., 606 F.3d 34 (2nd Cir. 2010)

(11 U.S.C. Sec. 526(a)(4) which prohibits debt relief agencies from advising clients to incur additional debt in contemplation of bankruptcy is constitutional in light of U.S. Supreme Court's decision in Milavetz ; trial court's judgment holding the provision unconstitutional reversed).