Trustee Requesting Debtor to File MTD in Ch 7
Posted: Sun Nov 30, 2014 4:24 pm
Can you send that number again? It doesn't correspond to In re Hamm, and there are 1,100 cases under "Hamm."
On Saturday, November 29, 2014 4:05 AM, "'Wesley H. Avery' wavery@rpmlaw.com [cdcbaa]" wrote:
In re Hamm, 2:14-bk-21725-DS
Sent from my iPhone
On Nov 29, 2014, at 3:59, "Michael Manning mike@manninglawoffice.com [cdcbaa]" wrote:
>Hello all
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>I have another question I wanted to bounce off the group.
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>We have a debtor who has been representing himself pro per in a Ch 7 he filed. The estate had assets and he hired us to negotiate with the trustee. We've been able to reach terms that are agreeable to everyone and the Ch 7 trustee wants me to draft the motion to dismiss.
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>I've never actually drafted a MTD in a Ch 7. It should be relatively simple:
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>- debtor pays admin fees
>- debtor agrees to 180 day bar to refile
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>Like I said, pretty straightforward. However, if anyone has a template or any suggestions regarding any details that might be relevant to a motion such as this I would be very grateful.
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>Thanks
>Mike
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>Mike Manning
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>4667 MacArthur Blvd., Suite 150 | Newport Beach, California 92660
>o 949.200-8757 ext 1009 | f 866.843.8308
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>mike@manninglawoffice.com
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