Chapter 7 Success Lawyers Chicago - Motion To Avoid Judicial Lien

UNITED STATES BANKRUPTCY COURT
NORTHERN DISTRICT OF ILLINOIS - EASTERN DIVISION

DEBTOR,
DEBTOR,
CHAPTER 7
JUDGE BARLIANT

MOTION TO AVOID JUDICIAL LIEN OF
THEODORE FRAZEK IN THE AMOUNT OF $54,678.43

Now come DEBTOR and DEBTOR, by their attorney, DAVID M. SIEGEL, and move the Court pursuant to Sec 522(f)1 of the Bankruptcy Code, to avoid the judicial lien of LIEN HOLDER'S NAME on the real estate commonly known as 15234 Barrister Street, Dolton, IL 60419, based upon the following:
1. That the debtors own the house commonly known as 15234 Barrister Street, Dolton, Illinois; that the fair market value of the house is $70,000.00.
2. That there is a mortgage balance on said property as of December 16, 1998 of approximately $52,000.00 payable to NATIONS BANK MORTGAGE CORP., P.O. BOX 4444, BUFFALO, NY 14270-4444.
3. That a judicial lien was placed by LIEN HOLDER'S NAME in the amount of $54,678.43 by obtaining a judgment against the debtors for $54,678.43 in the Circuit Court of Cook County, Illinois, in case number 96L 6164.
4. That debtors are entitled to a homestead exemption of $15,000.00, which they have claimed in their bankruptcy Schedule C, a copy of said is attached hereto.
5. That the judicial lien impairs the exemption of the debtors.

WHEREFORE, the debtors ask the Court to enter an order avoiding the judicial lien of LIEN HOLDER'S NAME in the amount of $54,678.43.

________________________________
Attorney for debtors

DAVID M. SIEGEL

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