Chapter 7 Success Lawyers Chicago - Motion For Leave To Sell Real Property

IN THE UNITED STATES BANKRUPTCY COURT
FOR THE NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION

IN THE MATTER OF:
CHAPTER 13
JOSEPH DEBTOR
DEBTOR

MOTION FOR LEAVE TO SELL REAL PROPERTY

NOW COMES the Debtor, JOSEPH DEBTOR, by and through his attorney, DAVID M. SIEGEL, and in support of his Motion, states:

1. That JOSEPH DEBTOR is the Debtor for the above captioned Motion.

2. That said Chapter 13 Petition was filed on 3/7/97.

3. That Debtor is a co-owner (Lawrence) of the property located at 16650 W. McDonald Drive. Lockport, IL 60441.

4. That Debtor does not reside in said property, rather, it is occupied by Debtor's Father.

5. That Debtor's Father makes all mortgage and tax payments for said property and will receive all equity derived from the sale of said property.

6. That the lien holder for said property, Savings of America, is not a party to the Chapter 13 plan, thus not receiving any plan payments.

7. That Debtor wishes to sell along with his co-owner Father, any interest that they may have in said property. (A copy of the pending real estate contract is hereby attached and marked exhibit 1).

8. That the sale of said property does not prejudice any creditors in that Debtor will not be receiving any disbursement thereof and that said property is not receiving any benefits under the plan.

WHEREFORE, Debtor respectfully requests that this honorable court grant Debtor's Motion for Leave to Sell Real Property co-owned by Debtor.
Respectfully Submitted,
______________________________
DAVID M. SIEGEL

ATTORNEY FOR DEBTOR
DAVID M. SIEGEL
Attorney For Debtor

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