How can I save this motion? Will an errata work? amen=
Posted: Fri Feb 10, 2012 3:13 pm
Amend with a new hearing date so you do not have a due process argument against you.
d
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To: cdcbaa@yahoogroups.com
Sent: Friday, February 10, 2012 10:41 AM
Subject: Re: [cdcbaa] How can I save this motion? Will an errata work? amend?
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. RomeroLaw 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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