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A certificate of service is to be filed with the Motion. 2. The Debtor(s) will complete the Disclosure of Information Regarding Domestic Support.Other Courts take a more relaxed approach and allow a hardship discharge "due to economic circumstances that did not exist nor were foreseeable at the time of. In chapter 13 cases, the debtor must file all required tax returns for tax periods ending within 4 years of the filing of the bankruptcy petition. In such situations, you may ask the court to grant a "hardship discharge. FACTS. The Lizzi Bankruptcy. On January 18, 2009, Debtor Frank Lizzi filed a voluntary petition for relief under chapter 13 of the Bankruptcy Code. In such situations, the debtor may ask the court to grant a "hardship discharge. " 11 U.S.C. § 1328(b). A Chapter 13 debt discharge is a court order releasing the debtor of all debts that are dischargeable.