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How can I save this motion? Will an errata work? amend?

Posted: Fri Feb 10, 2012 10:41 am
by Yahoo Bot

Why not review the property records at the county recorder's office and
figure out who the lienholder of record is? I started using LotBooks and
they have done a good job of providing these records.
On Fri, Feb 10, 2012 at 12:59 AM, Daniela Romero wrote:
> **
>
>
> Hi mates,
>
> I filed a Motion to avoid jr. lien, naming both Select Portfolio Servicing
> and Chase Bank as jr. lien holders in the Notice of Motion. Mortgage
> payments go to Select, but I have correspondence between Select and Debtor
> indicating that Chase is the lienholder. In the body of the "form" motion,
> I mistakenly only named Chase Bank as 2nd lienholder and I believe I should
> have also named Select Portfolio, too.
>
> All parties were properly served, including Select Portfolio. Will an
> errata work? amend motion with new hearing date? It is less than 14 days
> prior to hearing and this is in Riverside. Thanks!
>
> Sincerely,
> *
>
> Daniela P. Romero*
> *Law Office of Daniela P. Romero, APLC*
> *1015 North Lake Ave., Ste. 212*
> *Pasadena, CA 91104*
> *Tel: (626) 817-2611*
> *Fax: (626) 296-6991*
> *email: dromerolaw@gmail.com *
> *web: www.pasadenabankruptcylaw.com*
> ______________________________________________________________
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Kirk Brennan, esq.
California Law Office, P.C.
www.calibankruptcysite.com
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letters containing the signature of a director.
Why not review the property records at the county recorder's office and figure out who the lienholder of record is? I started using LotBooks and they have done a good job of providing these records.
On Fri, Feb 10, 2012 at 12:59 AM, Daniela Romero <dromerolaw@gmail.com> wrote:
Hi mates,I filed a Motion to avoid jr. lien, naming both Select Portfolio Servicing and Chase Bank as jr. lien holders in the Notice of Motion. Mortgage payments go to Select, but I have correspondence between Select and Debtor indicating that Chase is the lienholder. In the body of the "form" motion, I mistakenly only named Chase Bank as 2nd lienholder and I believe I should have also named Select Portfolio, too.
All parties were properly served, including Select Portfolio. Will an errata work? amend motion with new hearing date? It is less than 14 days prior to hearing and this is in Riverside. Thanks!
Sincerely,Daniela P. Romero
Law Office of Daniela P. Romero, APLC1015 North Lake Ave., Ste. 212Pasadena, CA 91104Tel: (626) 817-2611
Fax: (626) 296-6991email: dromerolaw@gmail.com
web: www.pasadenabankruptcylaw.com
______________________________________________________________NOTICE: This email (including attachments) is covered by the Electronic Communications Privacy Act, 18 U.S.C. 2510-2521. The information herein is confidential, privileged & exempt from disclosure under applicable law.the addressee hereof. If you are not the intended recipient of this message, you are prohibited from reading, disclosing, reproducing, distributing, disseminating, or otherwise using this transmission. The originator of this email and its affiliates do not represent, warrant or guarantee that the integrity of this communication has been maintained or that this communication is free of errors, viruses or other defects. Delivery of this message or any portions herein to any person other than the intended recipient is not intended to waive any right or privilege. If you have received this message in error, please promptly notify the sender by email and immediately delete this message.
My profiles:
-- Kirk Brennan, esq.California Law Office, P.C.www.calibankruptcysite.comCONFIDENTIALITY NOTICE: This e-mail and any attachments are for the exclusive and confidential use of the intended recipient. If you are not the intended recipient, please do not read, distribute or take action in reliance on this message. If you have received this message in error, please notify us immediately by return e-mail and promptly delete this message and its attachments from your computer system. We do not waive attorney-client or work product privilege by the transmission of this message.
TAX ADVICE NOTICE: Tax advice, if any, contained in this e-mail does not constitute a "reliance opinion" as defined in IRS Circular 230 and may not be used to establish reasonable reliance on the opinion of counsel for the purpose of avoiding the penalty imposed by Section 6662A of the Internal Revenue Code. The firm provides reliance opinions only in formal opinion letters containing the signature of a director.

The post was migrated from Yahoo.

How can I save this motion? Will an errata work? amend?

Posted: Fri Feb 10, 2012 3:11 am
by Yahoo Bot

I would completely redo the motion and put in the motion about the error in the first motion. Reserve with full notice and hearing period.
This could save you allot trouble if five years down the road the creditor wakes up and causes trouble.
Jonathan Leventhal, Esq.
Leventhal Law Group, P.C.
818-347-5800
To: CDCBAA
Sent: 02/10/2012 1:00 AM
Subject: [cdcbaa] How can I save this motion? Will an errata work? amend?
Hi mates,
I filed a Motion to avoid jr. lien, naming both Select Portfolio Servicing and Chase Bank as jr. lien holders in the Notice of Motion. Mortgage payments go to Select, but I have correspondence between Select and Debtor indicating that Chase is the lienholder. In the body of the "form" motion, I mistakenly only named Chase Bank as 2nd lienholder and I believe I should have also named Select Portfolio, too.
All parties were properly served, including Select Portfolio. Will an errata work? amend motion with new hearing date? It is less than 14 days prior to hearing and this is in Riverside. Thanks!
Sincerely,
Daniela P. Romero
Law Office of Daniela P. Romero, APLC
1015 North Lake Ave., Ste. 212
Pasadena, CA 91104
Tel: (626) 817-2611
Fax: (626) 296-6991
email: dromerolaw@gmail.com
web: www.pasadenabankruptcylaw.com

The post was migrated from Yahoo.

How can I save this motion? Will an errata work? amend?

Posted: Fri Feb 10, 2012 12:59 am
by Yahoo Bot

Hi mates,
I filed a Motion to avoid jr. lien, naming both Select Portfolio Servicing
and Chase Bank as jr. lien holders in the Notice of Motion. Mortgage
payments go to Select, but I have correspondence between Select and Debtor
indicating that Chase is the lienholder. In the body of the "form" motion,
I mistakenly only named Chase Bank as 2nd lienholder and I believe I should
have also named Select Portfolio, too.
All parties were properly served, including Select Portfolio. Will an
errata work? amend motion with new hearing date? It is less than 14 days
prior to hearing and this is in Riverside. Thanks!
Sincerely,
*
Daniela P. Romero*
*Law Office of Daniela P. Romero, APLC*
*1015 North Lake Ave., Ste. 212*
*Pasadena, CA 91104*
*Tel: (626) 817-2611*
*Fax: (626) 296-6991*
*email: dromerolaw@gmail.com *
*web: www.pasadenabankruptcylaw.com*

The post was migrated from Yahoo.