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Motion to avoid two liens
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Dear Listmates,
A while ago I asked the group whether I needed to file one motion or two to avoid two liens arising from the same debt. The debt was originally a second mortgage on which the creditor had obtained a judgment and recorded a judgment lien, but had not subsequently reconveyed the second deed of trust to my client. I received some interesting suggestions from the group, and decided to file one motion. Based on that motion the creditor agreed to stipulate to the avoidance of the judgment lien and the immediate reconveyance of the second deed of trust. Yesterday Judge Klein entered the order approving the stipulation.
I thought the motion might be useful for anyone else facing this somewhat unusual situation, and have therefore attached the Word version, without the exhibits.
Nick
Nicholas Gebelt, Ph.D., J.D.
Board Certified Bankruptcy Specialist
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Law Offices of Nicholas Gebelt
15150 Hornell Street
Whittier, CA 90604
Phone: 562.777.9159
FAX: 562.946.1365
Email: ngebelt@goodbye2debt.com; ngebelt@gebeltlaw.com
Web: www.goodbye2debt.com
Blog: www.southerncaliforniabankruptcylawblog.com/
We are a debt relief agency. We help people file for bankruptcy relief under the Bankruptcy Code.
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