Wondering if its possible to resolve treatment of a second lien (i.e. as
unsecured) without first filing a motion to value, LAM or AP? I imagine the
answer is yes but just wanted to be sure. If so, what would be the proper
ECF event codes for this.
Also have a similar situation with valuation of a car for purposes of
cramming down in the plan. Car creditor filed a POC showing a higher amount
but told us theyd be willing to stipulate to the amount we proposed in the
plan rather than just amend their POC, weird. (Although I thought our plan
treatment re value should control and car creditors proper course of action
would have been to file an objection to confirmation, instead the trustee
filed an objection to confirmation based on their POC.) Do we have to object
to the POC then settle with stipulation or can we just stipulate as our
first response?
N. Stephen Vokshori, Esq.
Managing Attorney
213-986-4323 x100 (direct) | 310-881-6996 (fax)
stephen@voklaw.com (email) |
www.VokLaw.com (website)
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