Creditor offers Stip before Lam motion filed. Should Lam motion still

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Listmates,
Chapter 13. At the time when I was preparing a Lam motion, the 2nd
mortgage creditor emailed me with an offer to stipulate that 2nd mortgage
is fully unsecured.
Do I still need to file a Lam motion or can I simply prepare the
stipulation, have it signed and file it?
Alik Segal
Alik.Segal@gmail.com
310-362-6157
California Central District
Listmates,Chapter 13. At the time when I was preparing a Lam motion, the 2nd mortgage creditor emailed me with an offer to stipulate that 2nd mortgage is fully unsecured. Do I still need to file a Lam motion or can I simply prepare the stipulation, have it signed and file it?
-- Alik SegalAlik.Segal@gmail.com310-362-6157California Central District

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