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IN RE MWANGI

No. 12-16087.

764 F.3d 1168 (2014)

In the Matter of Eric Njau MWANGI; Pauline Muthoni Mwicharo, Debtors. Eric Njau Mwangi; Pauline Muthoni Mwicharo, Appellants, v. Wells Fargo Bank, N.A., Appellee.

United States Court of Appeals, Ninth Circuit.

Filed August 26, 2014.

Attorney(s) appearing for the Case

Christopher P. Burke (argued), Las Vegas, NV, for Plaintiffs-Appellants.

M. David Minnick (argued), Kevin M. Fong , and Daniel Lamb , Pillsbury Winthrop Shaw Pittman LLP, San Francisco, CA; Lance Earl and Lars K. Evensen , Holland & Hart LLP, Las Vegas, NV, for Defendant-Appellee.

Before: BARRY G. SILVERMAN, WILLIAM A. FLETCHER, and JAY S. BYBEE, Circuit Judges.

OPINION

BYBEE, Circuit Judge:

Eric Mwangi and Pauline Mwicharo (collectively "the Debtors") were account holders at Wells Fargo Bank, N.A. When Wells Fargo discovered that the Debtors had filed a voluntary Chapter 7 bankruptcy petition, it placed a "temporary administrative pledge" on the Debtors' accounts. Wells Fargo then requested instructions from the Chapter 7 trustee regarding the distribution of account funds, a portion of which the Debtors claimed...

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