stipulation of lien strip complaint [1 Attachment]
Posted: Mon Dec 05, 2011 9:28 am
No
Stip:
Background Facts:
Debtor owns x
Creditor owed y, with z lien.
The debtor wishes to value the property subject to the lien for all purposes in the Bk as $. .
Creditor does not oppose valuation.
Now Therefore debtor and creditor stipulate:
Value of property for all purposes in this Bk case is $
Signature
Signature.
Sent from my iPhone
On Dec 4, 2011, at 11:51 PM, Kirk Brennan wrote:
> [Attachment(s) from Kirk Brennan included below]
> Attached is the model order for Judge Zurzolo.
>
> I'm wondering if a pre-trial stipulation can be lodged when no complaint has yet been filed.
>
> Any of you ever tried to do this?
>
>
>
>
> On Mon, Nov 28, 2011 at 1:21 PM, Dennis McGoldrick wrote:
>
> take out the language referring to the complaint.
>
> To: Cdcbaa Yahoo Listserv
> Sent: Sunday, November 27, 2011 12:31 PM
>
> Subject: [cdcbaa] stipulation of lien strip complaint
>
>
> Haven't yet filed a lien strip complaint to remove the 2nd DOT, and the 2nd DOT lender has reached out stating a willingness to stipulate.
>
> The only stipulated model order I see addresses complaints that have already been filed. Any suggestions?
>
>
>
> --
> Kirk Brennan, esq.
> California Law Office, P.C.
> calibankrutpcysite.com
>
> CONFIDENTIALITY 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.
>
>
>
>
>
>
> --
> Kirk Brennan, esq.
> California Law Office, P.C.
> calibankrutpcysite.com
>
> CONFIDENTIALITY 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.
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>
NoStip:Background Facts:Debtor owns xCreditor owed y, with z lien.The debtor wishes to value the property subject to the lien for all purposes in the Bk as $. . Creditor does not oppose valuation.Now Therefore debtor and creditor stipulate:Value of property for all purposes in this Bk case is $SignatureSignature. Sent from my iPhoneOn Dec 4, 2011, at 11:51 PM, Kirk Brennan <kirkinhermosa@gmail.com> wrote:
Attached is the model order for Judge Zurzolo.I'm wondering if a pre-trial stipulation can be lodged when no complaint has yet been filed. Any of you ever tried to do this?
On Mon, Nov 28, 2011 at 1:21 PM, Dennis McGoldrick <easky1@yahoo.com> wrote:
take out the language referring to the complaint.
From: Kirk Brennan <kirkinhermosa@gmail.com>
To: Cdcbaa Yahoo Listserv <cdcbaa@yahoogroups.com> Sent: Sunday, November 27, 2011 12:31 PM
Subject: [cdcbaa] stipulation of lien strip complaint
Haven't yet filed a lien strip complaint to remove the 2nd DOT, and the 2nd DOT lender has reached out stating a willingness to stipulate. The only stipulated model order I see addresses complaints that have already been filed. Any suggestions?
-- Kirk Brennan, esq.California Law Office, P.C.calibankrutpcysite.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.
-- Kirk Brennan, esq.California Law Office, P.C.calibankrutpcysite.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.