Motion to reopen to move to avoid lien

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I've been brought into a Chapter 7 case that's been discharged and closed; the debtor should have filed a motion to avoid a lien but did his case pro se and botched the job. Now he wants me to reopen the case to file the motion.
Anyone have a motion to reopen for this purpose they can let me crib?
Case is in Santa Barbara if that makes any difference.
Thanks in advance.
Jay S. Fleischman, Esq.
Shaev & Fleischman, LLP
I help people in the Los Angeles area and New York City get smart solutions to their bill problems.
http://www.ConsumerHelpCentral.com
556 S Fair Oaks Ave Ste 101-152
Pasadena CA 91105-2656
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New York NY 10118
T: 626-808-4343 x704
E: jay@sflawca.com
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