Motion to reopen to reaffirm

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Client wanted to reaffirm car with Wachovia. She signed papers; we sent them to Wachovia, who now claims they never got them;
never uploaded them, and they want to repo the car. Case was closed last month. If we do a motion to reopen to reaffirm they will let her keep the car and not repo but will give her better terms.
If I do a motion to re-open to file a reaffirmation do I need to include a copy of the new agreement.
I am guessing this is just a captioned pleading and will need a new filing fee. any suggestions?
Margaret Norman
111 N. Sepulveda Blvd. #355
Manhattan Beach, Ca.
310-376-7873
Client wanted to reaffirm car with Wachovia. She signed
papers; we sent them to Wachovia, who now claims they never got them;
never uploaded them, and they want to repo the car. Case was
closed last month. If we do a motion to reopen to reaffirm they will let her
keep the car and not repo but will give her better terms.
If I do a motion to re-open to file a reaffirmation do I
need to include a copy of the new agreement.
I am guessing this is just a captioned pleading and will
need a new filing fee. any suggestions?
Margaret Norman
111 N. Sepulveda Blvd. #355
Manhattan Beach, Ca.
310-376-7873

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