Judge Zurzolo's valuation date for a Motion to Value =

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He uses the Confirmation date.
Keith Higginbotham
cdcbaacheck@aol.com
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To: cdcbaa
Sent: Sat, Feb 4, 2017 11:59 am
Subject: [cdcbaa] Re: Judge Zurzolo's valuation date for a Motion to Value Collateral (Real Property) - Not to be confused with Adversary to Avoid Junior Lien
Good Afternoon All,
Does anyone know the date that Judge Zurzolo uses for a motion to value collateral on real property (i.e. filing date, confirmation date, or date the motion is filed)? I know that for an adversary to avoid a junior lien he does not follow In re Gutierrez and uses the confirmation hearing date. However, because he schedules chapter 13 confirmation hearings approximately one year after a case is filed, I doubt the confirmation hearing date is the probative date for valuation purposes.
Regards,
Stephen Smyth
He uses the Confirmation date.
Keith Higginbotham
cdcbaacheck@aol.com
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To: cdcbaa <cdcbaa@yahoogroups.com>
Sent: Sat, Feb 4, 2017 11:59 am
Subject: [cdcbaa] Re: Judge Zurzolo's valuation date for a Motion to Value Collateral (Real Property) - Not to be confused with Adversary to Avoid Junior Lien


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