that: a) the debtor has paid in full the amount required to cure the default on the claim, and b) the debtor is otherwise current on all payments consistent with 11 U.S.C. § 1322(b)(5). 8a. [Alternative In response to this Notice, [mortgage filed a statement on [date] A] holder] as a supplement to its proof of claim indicating that fees, expenses, and charges in the amount of [$amount] are due and unpaid, and that post-petition mortgage payments in the amount of [$amount] are due and unpaid. The alleged fees, expenses and charges, and post-petition mortgage payments have been paid by the debtors or are not required to cure the default or maintain payments in accordance with 11 U.S.C. § 1322(b)(5) for the following reasons: [list fees and payments and explanation why not due]. 8b. [Alternative Despite the requirement in Bankruptcy Rule 3002.1(g) to file a statement B] in response to this Notice, [mortgage failed to file and serve such a statement within 21 holder] days after service of the Notice. All fees, expenses, and charges asserted as recoverable against the debtors or the debtors’ residence in the Notices of Post-petition Mortgage Fees, Expenses, and Charges filed by [mortgage during the pendency of this Chapter 13 case have either been paid by the holder] debtors or the court has determined that they are not required to cure the default or maintain payments in accordance with 11 U.S.C. § 1322(b)(5). The debtors have made all of their post-petition mortgage payments to [mortgage holder] up to and including the date of the filing of this motion. WHEREFORE, the debtors request this Court enter an Order: a. Declaring that the debtors’ mortgage loan has been cured so that it is current as of the date of the order granting this motion in connection with any alleged default on their mortgage or otherwise, that have not been approved by this Court through the allowance of the claim of
that: a) the debtor has paid in full the amount required to cure the default on the claim, and b) the debtor is otherwise current on all payments consistent with 11 U.S.C. § 1322(b)(5). 8a. [Alternative A] In response to this Notice, [mortgage holder] filed a statement on [date] as a supplement to its proof of claim indicating that fees, expenses, and charges in the amount of [$amount] are due and unpaid, and that post-petition mortgage payments in the amount of [$amount] are due and unpaid. The alleged fees, expenses and charges, and post-petition mortgage payments have been paid by the debtors or are not required to cure the default or maintain payments in accordance with 11 U.S.C. § 1322(b)(5) for the following reasons: [list fees and payments and explanation why not due]. 8b. [Alternative B] Despite the requirement in Bankruptcy Rule 3002.1(g) to file a statement in response to this Notice, [mortgage holder] failed to file and serve such a statement within 21 days after service of the Notice. All fees, expenses, and charges asserted as recoverable against the debtors or the debtors’ residence in the Notices of Post-petition Mortgage Fees, Expenses, and Charges filed by [mortgage holder] during the pendency of this Chapter 13 case have either been paid by the debtors or the court has determined that they are not required to cure the default or maintain payments in accordance with 11 U.S.C. § 1322(b)(5). The debtors have made all of their post-petition mortgage payments to [mortgage holder] up to and including the date of the filing of this motion. WHEREFORE, the debtors request this Court enter an Order: a. Declaring that the debtors’ mortgage loan has been cured so that it is current as of the date of the order granting this motion in connection with any alleged default on their mortgage or otherwise, that have not been approved by this Court through the allowance of the claim of