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We will gladly accept referrals for any and all LAM Motion cases....
But in reality - they are not that difficult and following Lou's lead is a great place to start...and finish...
To: cdcbaa@yahoogroups.com
Sent: Wednesday, April 29, 2009 10:33:20 AM GMT -08:00 US/Canada Pacific
Subject: RE: [cdcbaa] LAM Motion Service
Indeed. I'd like to find someone who can do that, but I can't figure out
how to make that work in a Chapter 13 context. Problem is with our local
rules because it requires an attorney in a Chapter 13 case to handle everyaspect of the Ch. 13 case from start to finish (and, according to Hank
Toles, beyond). In a chapter 11 you could just theoretically hire special
counsel (upon approval by the court). It sucks (to use a legal term)
because there are a lot of Ch. 13 cases I don't feel like handling becauseof the LAM motion (especially those that might end up in a certain downtowncourtroom) but I hate giving up the whole case just because of that.
*************************
Mark J. Markus
Law Office of Mark J. Markus
11684 Ventura Blvd. PMB #403
Studio City, CA 91604-2652
(818)509-1173 (818)509-1460 (fax)
Toll Free: 1-866-576-6275
web: http://www.bklaw.com/
This Firm is a Qualified Federal Debt Relief Agency (see what this means athttp://bklaw.com/bankruptcy-blog/2008/09/debt-relief-agencies-definition/ )________________________________________________
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Margaret Norman
Sent: Wednesday, April 29, 2009 10:01 AM
To: cdcbaa@yahoogroups.com ; Law Offices of Louis J. Esbin
Subject: Re: [cdcbaa] LAM Motion Service
When I first saw the subject line I thought somebody just does LAM
motions. For a set pricethey do it all. There's an idea for a niche
practice.
Marge Norman
On Wed, 29 Apr 2009 06:40:23 -0000
"Law Offices of Louis J. Esbin" wrote:
> Woodland Hills Bankruptcy Judges agree that senior lienholders need
>not be served with LAM Motion. Be aware, however, that they are
>requiring greater attention to the following:
>
> 1. Follow LBR on identifying effected lienholders in the caption,
>in the body of the motion, and make sure that it is clear.
> 2. Follow LBR on setting forth the amount of the lienholder
>interest to be effected.
> 3. If a claim has been filed, refer to the claim number on the
>claims docket, the date filed, and the amount of the claim, in which
>case you may not be required to attach claim, but judges will confer
>within one another if reference is adequate notice (maybe trying to
>prevent system overload with needless documents filed).
> 4. If a claim is not filed, need to establish priority of liens,
>amount and proper party in interest. Use TILA and California
>Beneficiary Demand Statement to obtain documents from lenders.
> 5. Don't forget to include unpaid real property taxes as priority
>to senior lienholder. Has HOA perfected lien?
> 6. Check SOS website for agent for service of process for lenders
>and loan servicers, and on that point, serve beneficiary under deed
>of trust and loan servicer.
> 7. If no agent for service of process, and claim has not been filed
>with address where notice should be sent, Google entity and look up
>in "contact us" for any addresses to which service would be sent.
> 8. Admissible evidence of value.
>
> The foregoing reflects issues raised during today's LAM Motion
>calender.
>
> Lou Esbin
>
Margaret Norman, Attorney
111 N. Sepulveda Blvd. #355
Manhattan Beach, Ca. 90266
310-376-7873
Fax-310-798-9846
WWW:Margeslaw.com
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p { margin: 0; }We will gladly accept referrals for any and all LAM Motion cases....
But in reality - they are not that difficult and following Lou's lead is a great place to start...and finish...----- Original Message -----omSent: Wednesday, April 29, 2009 10:33:20 AM GMT -08:00 US/Canada PacificSubject: RE: [cdcbaa] LAM Motion Service
Indeed. I'd like to find someone who can do that, but I can't figure outhow to make that work in a Chapter 13 context. Problem is with our localrules because it requires an attorney in a Chapter 13 case to handle everyaspect of the Ch. 13 case from start to finish (and, according to HankToles, beyond). In a chapter 11 you could just theoretically hire specialcounsel (upon approval by the court). It sucks (to use a legal term)because there are a lot of Ch. 13 cases I don't feel like handling becauseof the LAM motion (especially those that might end up in a certain downtowncourtroom) but I hate giving up the whole case just because of that.*************************Mark J. MarkusLaw Office of Mark J. Markus11684 Ventura Blvd. PMB #403Studio City, CA 91604-2652(818)509-1173 (818)509-1460 (fax)Toll Free: 1-866-576-6275web: http://www.bklaw.com/This Firm is a Qualified Federal Debt Relief Agency (see what this means athttp://bklaw.com/bankruptcy-blog/
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