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Two motions or one?
I think you only need one because the deed of trust is invalid, and the
judge could refuse to hear the 506 motion because it is moot or not
ripe.
If they haven't filed a reconveyance of the deed of trust already they
are in violation of state law requiring it. Have you double checked
with a title company on the state of the property record?
The only bankruptcy motion needed is the 522f.
The 506 would be more akin to removing a cloud on title - a dead deed of
trust. Try a letter requesting its reconveyance and look into the state
law which may entitle you to legal fees.
Steven B. Lever
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>
> I inherited a case where the consensual lien and the judgment lien on the
> same property were actually eliminated through a 506 motion alone in front
> of Judge Neiter. In fact, he entered the Ch. 11 plan confirmation order
> today.
>
> --
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or, instead of doing Motions you could do it all by one Complaint
(although that might run afoul of the requirement to use the
mandatory 522f forms).
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