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Turnover Motion
Bert,
I just sent you one.
Nina Javan
Margulies Faith, LLP
On Thu, Aug 27, 2015 at 11:14 AM, Bert Briones bertbri@ymail.com [cdcbaa] wrote:
>
>
>
> I need to file a motion for turnover in a chapter 13 case. The funds in
> question were paid to Bank of America, N.A. on mortgage arrears. An
> Objection to Claim was filed and granted disallowing a portion of the
> original claim.
> Now the case is nearly ending, but the Debtor is short and needs the
> disallowed funds to be turned-over to the chapter 13 trustee to
> successfully complete the chapter 13 plan. The trustee and debtors
> counsel have both attempted to informally recover the disallowed funds but
> no response yet. I suspect part of the problem is that BA has assigned the
> servicing to Green Tree Servicing who is referring me to their counsel.
> Therefore, I need to file a motion for turnover immediately.
>
> I have never done one of these motions.
>
> Does anyone have a sample of such a motion that they would be willing to
> share?
>
> If so please send to bb@redhilllawgroup.com
>
> Thanks, Bert Briones
>
>
>
>
>
>
Bert,I just sent you one.Nina JavanMargulies Faith, LLPOn Thu, Aug 27, 2015 at 11:14 AM, Bert Briones bertbri@ymail.com [cdcbaa] <cdcbaa@yahoogroups.com> wrote:
The post was migrated from Yahoo.
I need to file a motion for turnover in a chapter 13 case. The funds in question were paid to Bank ofAmerica, N.A. on mortgage arrears. AnObjection to Claim was filed and granted disallowing a portion of the original claim.
Now the case is nearly ending, but the Debtor is short andneeds the disallowed funds to be turned-over to the chapter 13 trustee tosuccessfully complete the chapter 13 plan.The trustee and debtors counsel have both attempted to informallyrecover the disallowed funds but no response yet.o Green TreeServicing who is referring me to their counsel. Therefore, I need to file a motion for turnover immediately.
I have never done one of these motions.
Does anyone have a sample of such a motion that they wouldbe willing to share?
If so please send to bb@redhilllawgroup.com
Thanks, Bert Briones
The post was migrated from Yahoo.