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Client ran up a bill of $2,400. Client filed Bankruptcy but only listed $1,200 on the BK schedule. Client sent me an email asking for continued representation and so I finished his case for $600 more. Client failed to pay me and I sued him in small claims for $1,800 (2,400 - $1,200 discharged + $600). Client hired a debt defense atty and filed a motion to reopen the Bankruptcy which was granted. Now client is filing a motion to stay enforcement of the Judgment and $5,000 in sanctions claiming:1) the $600 is no good because there was no formal reaffirmation agreement just the email, and 2) the amount owed was only $1,200 not $2,400 but I have the invoices. Do I just filed my response to the BK motion with my own request for $5,000 in sanction for filing a bogus motion?