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If no opposition to 362(d) motion-auto, is it better

Posted: Wed Feb 03, 2010 8:42 pm
by Yahoo Bot

That was my original thoughts with respect to filing nonop.
On Wed, Feb 3, 2010 at 8:25 PM, Dennis McGoldrick wrote:
>
>
> In the old days it was considered a courtesy to the court to file a nonop.
> Court doen't have to look for a reply, or workup the case.
>
> Dennis McGoldrick
> 350 S. Crenshaw Bl., #A207B
> Torrance, CA 90503
>
> On Feb 3, 2010, at 9:16 AM, Daniela Romero wrote:
>
>
>
> Hi all,
>
> Would like to know what is the better practice. It's really hard for me
> not to file a response indicating there is no opposition on the part of the
> debtor.
>
> Facts: Debtor forgot to advise me that he co-signed auto loan for niece;
> creditor advised me of loan; I amended schedules and they filed RFS; niece
> is 3 months in arrears, in Colorado and debtor has no interest in car; in
> fact, he does not know her exact whereabouts;
>
> Creditor filed 362 motion in debtors name alone--I asked that they amend to
> include niece and they did; debtor has no opposition to motion. car is
> valued at 11k and 3k owed
>
> What is the better practice? FIle response indicating non opp? or just let
> it go without filing response?
>
> Thanks,
>
> --
> Daniela P. Romero
> Law Office of Daniela Romero, APLC
> 1015 N. Lake Ave., Ste. 115
> Pasadena, CA 91104
> Telephone:626-817-2611
> Facsimile: 626-628-1781
> email: dromerolaw@gmail.com
>
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Daniela P. Romero
Law Office of Daniela Romero, APLC
1015 N. Lake Ave., Ste. 115
Pasadena, CA 91104
Telephone:626-817-2611
Facsimile: 626-628-1781
email: dromerolaw@gmail.com
NOTICE: This E-mail (including attachments) is covered by the Electronic
Communications Privacy Act, 18 U.S.C. 2510-2521. The information herein
is confidential, privileged & exempt from disclosure under applicable law.
This E-mail (including attachments) are intended solely for the use of the
addressee hereof. If you are not the intended recipient of this message,
you are prohibited from reading, disclosing, reproducing, distributing,
disseminating, or otherwise using this transmission. The originator of this
e-mail and its affiliates do not represent, warrant or guarantee that the
integrity of this communication has been maintained or that this
communication is free of errors, viruses or other defects. Delivery of this
message or any portions herein to any person other than the intended
recipient is not intended to waive any right or privilege. If you have
received this message in error, please promptly notify the sender by e-mail
and immediately delete this message.
To comply with IRS regulations, we advise you that any discussion of Federal
tax issues in this e-mail was not intended or written to be used, and cannot
be used by you, (i) to avoid any penalties imposed under the Internal
Revenue Code or (ii) to promote, market or recommend to another party any
transaction or matter addressed herein.
That was my original thoughts with respect to filing nonop. On Wed, Feb 3, 2010 at 8:25 PM, Dennis McGoldrick <easky1@yahoo.com> wrote:
In the old days it was considered a courtesy to the court to file a nonop. Court doen't have to look for a reply, or workup the case.Dennis McGoldrick350 S. Crenshaw Bl., #A207B
Torrance, CA 90503On Feb 3, 2010, at 9:16 AM, Daniela Romero <
Hi all,Would like to know what is the better practice. It's really hard for me not to file a response indicating there is no opposition on the part of the debtor.Facts: Debtor forgot to advise me that he co-signed auto loan for niece; creditor advised me of loan; I amended schedules and they filed RFS; niece is 3 months in arrears, in Colorado and debtor has no interest in car; in fact, he does not know her exact whereabouts;
Creditor filed 362 motion in debtors name alone--I asked that they amend to include niece and they did; debtor has no opposition to motion. car is valued at 11k and 3k owed What is the better practice? FIle response indicating non opp? or just let it go without filing response?
Thanks,-- Daniela P. RomeroLaw Office of Daniela Romero, APLC1015 N. Lake Ave., Ste. 115Pasadena, CA 91104Telephone:626-817-2611Facsimile: 626-628-1781email:
The post was migrated from Yahoo.

If no opposition to 362(d) motion-auto, is it better

Posted: Wed Feb 03, 2010 9:44 am
by Yahoo Bot

charset="windows-1251"
Too much time for too few dollars. No one really cares if you do or don't
file a notice of non-opposition. Just let it go without opposition or
appearance. They get the same result either way, but you have not spent
another 15 minutes on a flat fee case. If the case is an hourly case, I
would view filing non-oppositions as milking the case for fees - i.e.
unethical.
David A. Tilem
Certified Bankruptcy Specialist*
Law Offices of David A. Tilem (a debt relief agency)
206 N. Jackson Street, #201, Glendale, CA 91206
Tel: 818-507-6000 Fax: 818-507-6800
* Bankruptcy specialist cert. by State Bar of CA Bd of Legal
Specialization.
Henry Toles
Sent: Wednesday, February 03, 2010 9:29 AM
To: cdcbaa@yahoogroups.com
Subject: RE: [cdcbaa] If no opposition to 362(d) motion-auto, is it better
practice to file a response re non-opp? or just not respond at all?
I used to file non oppositions, but I no longer do so. My reasoning is that
I take a 2090 Limited Scope Retainer in all of my 7s (which I have limited
my practice to now in my semi-retirement). It is my opinion that plays heck
with the limited scope status of my case when I do (the 2090 is filed with
the case). When I was doing 13s and 11s, if I did not oppose the motion,
I did file a non opposition because there was no 2090 form for those cases.
This is a long winded way of saying I would in any case where I did not take
a limited scope 2090 retainer limitation.
Hank
_____

The post was migrated from Yahoo.