UNITED STATES BANKRUPTCY COURT FOR THE NORTHERN DISTRICT OF OHIO In re: ) Case No. ) [NAME OF DEBTOR(S)], ) Chapter <13> <11> ) Debtor(s). ) Judge < > ) ) MOTION OF <MOVANT> FOR ) RELIEF FROM STAY ) ) <ADDRESS OF REAL PROPERTY OR ) DESCRIPTION OF PERSONAL ) PROPERTY> <MOVANT> (the moves this Court, under Bankruptcy Code §§ 361, 362, and “Movant”) 363, and other sections of Title 11 of the United States Code, under Federal Rule of Bankruptcy Procedure 4001, and under for an order conditioning, modifying or dissolving the automatic stay imposed by Bankruptcy Code § 362. MEMORANDUM IN SUPPORT 1. The Court has jurisdiction over this matter under 28 U.S.C. §§ 157 and 1334. This is a core proceeding under 28 U.S.C. § 157(b)(2). The venue of this case and this motion is proper under 28 U.S.C. §§ 1408 and 1409. 2. On <DATE>, the < DEBTOR(S) AND/OR PERSON(S), STATE NAME(S) IF APPLICABLE> obtained a loan from <LENDER NAME> in the amount of <AMOUNT>. Such loan was evidenced by a <PROMISSORY NOTE> <OTHER> dated <DATE> (the a copy of which is attached as Exhibit A. “Note”), 3. To secure payment of the Note and performance of the other terms contained in it, the <DEBTOR(S) AND/OR OTHER PERSON(S), STATE NAME(S) IF APPLICABLE> executed a Security Agreement in favor of <STATE NAME> dated <DATE> (the “Security Agreement”). The Security Agreement granted a lien on the <DESCRIBE REAL AND/OR PERSONAL PROPERTY, INCLUDE ADDRESS IF REAL ESTATE> owned by <NAME OF DEBTOR(S) AND/OR OTHER PERSON(S), STATE NAME(S) IF APPLICABLE> (the The Collateral is more fully described in the Security Agreement (check one): “Collateral”).
UNITED STATES BANKRUPTCY COURT FOR THE NORTHERN DISTRICT OF OHIO In re: ) Case No. ) [NAME OF DEBTOR(S)], ) Chapter <13> <11> ) Debtor(s). ) Judge < > ) ) MOTION OF <MOVANT> FOR ) RELIEF FROM STAY ) ) <ADDRESS OF REAL PROPERTY OR ) DESCRIPTION OF PERSONAL ) PROPERTY> <MOVANT> (the “Movant”) moves this Court, under Bankruptcy Code §§ 361, 362, and 363, and other sections of Title 11 of the United States Code, under Federal Rule of Bankruptcy Procedure 4001, and under for an order conditioning, modifying or dissolving the automatic stay imposed by Bankruptcy Code § 362. MEMORANDUM IN SUPPORT 1. The Court has jurisdiction over this matter under 28 U.S.C. §§ 157 and 1334. This is a core proceeding under 28 U.S.C. § 157(b)(2). The venue of this case and this motion is proper under 28 U.S.C. §§ 1408 and 1409. 2. On <DATE>, the < DEBTOR(S) AND/OR PERSON(S), STATE NAME(S) IF APPLICABLE> obtained a loan from <LENDER NAME> in the amount of <AMOUNT>. Such loan was evidenced by a <PROMISSORY NOTE> <OTHER> dated <DATE> (the “Note”), a copy of which is attached as Exhibit A. 3. To secure payment of the Note and performance of the other terms contained in it, the <DEBTOR(S) AND/OR OTHER PERSON(S), STATE NAME(S) IF APPLICABLE> executed a Security Agreement in favor of <STATE NAME> dated <DATE> (the “Security Agreement”). The Security Agreement granted a lien on the <DESCRIBE REAL AND/OR PERSONAL PROPERTY, INCLUDE ADDRESS IF REAL ESTATE> owned by <NAME OF DEBTOR(S) AND/OR OTHER PERSON(S), STATE NAME(S) IF APPLICABLE> (the “Collateral”). The Collateral is more fully described in the Security Agreement (check one):
2011-motion-relief-stay-chapter-11-and-13-cases.docx