Turnover Motion
Posted: Thu Aug 27, 2015 4:01 pm
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:
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> 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.
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> I have never done one of these motions.
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> Does anyone have a sample of such a motion that they would be willing to
> share?
>
> If so please send to bb@redhilllawgroup.com
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> Thanks, Bert Briones
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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.