B-4003-2 (rev 10/1/12) UNITED STATES BANKRUPTCY COURT Southern District of Indiana In re: ) ) ) ) [Name of Debtor(s)], Debtor (s). Case No. (xx-xxxxx) MOTION TO AVOID (JUDICIAL) LIEN (ON HOUSEHOLD GOODS) AND NOTICE OF OBJECTION DEADLINE The debtor(s) hereby move(s) the Court, pursuant to 11 U.S.C. 522(f), to avoid the lien of (name of creditor) on the following (real/personal) property: [Describe real property by commonly known address or describe personal property by referring to the definition of “household goods” in 11 U.S.C. §522(f)(4)] - referred to as the”Property.” In support of the motion, the debtor(s) state(s) the following: 1. The debtor(s) filed this case on (date) - referred to as the “Petition Date.” 2. The creditor obtained a lien on the household goods listed above on (date debt was incurred that lien secures). -orThe creditor obtained a judgment which is a lien on the real property described above. That judgment was obtained pre-petition on (date) in (Court and case number). 3. The value of the Property as of the Petition Date is (value). 4. The creditor’s lien is in the approximate amount of (amount). 5. (If applicable) The amount of the impaired exemption is (amount). 1 American LegalNet, Inc. www.FormsWorkFlow.com B-4003-2 (rev 10/1/12) 6. The Property has been claimed as exempt. The lien impairs an exemption of the debtor(s) and is subject to avoidance under 11 U.S.C. §522(f). 7. The other lien(s) on the Property is/are as follows: [list creditor(s) and lien amount(s)]. 8. The lien(s) debtor will be seeking to avoid by separately filed motion(s) is/are as follows: [list creditor(s) and lien amount(s)]. NOTICE IS GIVEN that any objection must be filed with the Bankruptcy Clerk within 21 days from date of service [or such other time period as may be permitted by Fed.R. Bankr.P. 9006(f)]. Those not required or not permitted to file electronically must deliver any objection by U.S. mail, courier, overnight/express mail, or in person at: (Select the appropriate address.) Indianapolis 116 U.S. Courthouse 46 East Ohio St. Indianapolis, IN 46204 Evansville 352 Federal Bldg. 101 NW M.L. King Jr. Blvd. Evansville, IN 47708 New Albany 110 U.S. Courthouse 121 W. Spring St. New Albany, IN 47150 Terre Haute 104 U.S. Courthouse 921 Ohio St. Terre Haute, IN 47807 The objecting party must ensure delivery of the objection to the party filing the motion. If an objection is NOT timely filed, the requested relief may be granted. WHEREFORE, debtor(s) move(s) the Court to enter an order avoiding creditor’s (judicial) lien (on household goods) and granting such other relief as appropriate. /s/ Counsel for Debtor(s) Counsel for Debtor(s) (required signature block) CERTIFICATE OF SERVICE (See “Certificate of Service - Generic” on the Court’s website under “Forms/Local/Motions & Related Notices-Certificates of Service-Orders/Certificates of Service/Generic.”) 2 American LegalNet, Inc. www.FormsWorkFlow.com