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I am not a lawyer, but if my Business Law serves me correctly, I believe that some states protect retirement accounts, as well as life insurance cash values from creditors so long as the proceeds are kept under the "wrap" of the retirement plan or insurance product. However - all a creditor has to do is obtain a judgment and continue to keep it in force. Sooner or later a person will either die - or take distributions from his/her retirement/insurance accounts - at which time the judgment could be served and executed.

Here is a link regarding ROTH IRA protection
http://www3.state.id.us/oasis/1999/S1243.html
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