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the pan has to drop down farther to clear the filter. unless your salad fingers and can pop the filter off at the same time... better off just zipping 2 bolts loose and lift the tranny a couple inches. no biggie
The shape of the pan and available clearances. You HAVE to have additional clearance to get the sucker out of there! I removed the 4 bolts and jacked the back end of the transmission a little more than an inch and found one and one way only to get it out even then!