Central District Consumer Bankruptcy Attorney's Association

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Assert $100 interest in the property by amending schedule c. Then file a motion to avoid lien.-----Original Message-----
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Sent: May 3, 2015 7:11 PM
To: cdcbaa@yahoogroups.com
Subject: [cdcbaa] Avoiding liens on non-exempt real property

I have a client who has nonexempt real property (not primary residence) which Trustee has abandoned. It is in short sale but has 2 judicial liens. The Court's Motion to Avoid form refers only to "exempt" property. Query: one of the judicial lienholders will not release the liens, therefore they have to be avoided in order for the short sale to proceed. Is this a case where I prepare my own motion to avoid liens from real property abandoned by the Trustee? And provide all the same required information as in the court form?Thank you in advance for any responses.CraigCraig J. Beauchamp, Esq.Attorney at LawPO Box 25857Santa Ana, CA 92799(949) 689-9709(714) 835-5763 faxLegallycraig@gmail.comNO EX-PARTE NOTICE VIA VOICE MAIL OR EMAIL: I do not accept notice for Ex Parte Applications via voicemail or by email. You must comply with California Law and give notice to a person in my office during regular business hours.CONFIDENTIALITY STATEMENT: This message contains privileged and confidential information and is intended only for the individual named. If you are not the intended recipient you should not disseminate, distribute, store, print, copy or deliver this message. Please notify the sender immediately by e-mail if you have received this e-mail by mistake and delete this e-mail from your system.

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