Central District Consumer Bankruptcy Attorney's Association

The 522(f) form motion needs to be revised. I personally would not use it.
Sincerely,
*Michael Avanesian, Esq. *
Avanesian Law Firm
101 N. Brand Blvd. PH 1920
Glendale, CA 91203
Tel: 818.276.2477 | Fax: 818.208.4550
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On Thu, Oct 22, 2015 at 7:11 AM, Shannon Doyle
sdoyle@ebankruptcyassistants.com [cdcbaa] wrote:
>
>
> I have filed these motions many times with no issues but recently I had
> one wherein Judge Donovans clerk rejected the order avoiding lien because
> the evidence provided in the motion included the value of the home as of
> the date of filing and the first mortgage payoff as of the date of
> filing. The clerk stated the evidence needs to show the first mortgage
> payoff as of the *current date* (which happened to be three years after
> the date of filing) . I followed the clerks instructions and the order
> was entered but this didnt make sense to me. Why do you skew the equity
> analysis in this way using the value from the date of filing and the
> payoff from three years later? Is this just a Judge Donovan thing or am I
> completely missing something here? I have the same fact pattern with Judge
> Kaufman do I use the first mortgage payoff as of the date of filing or as
> of today?
>
>
>
> Thank you!
>
>
>
>
>
> [image: New Professional Pic2]
>
> Shannon A. Doyle
>
> *Attorney | Virtual Bankruptcy Assistant*
>
> *Phone: 855-378-4080 *
>
> *Fax: 562-249-8435 *
>
> [image: PetitionPartnD05bR08aP01ZL-Madison8a]
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The 522(f) form motion needs to be revised. I personally would not use it.
The post was migrated from Yahoo.