NM LF 4003-1 UNITED STATES BANKRUPTCY COURT DISTRICT OF NEW MEXICO In re: Case No. Debtor(s). MOTION TO AVOID JUDICIAL LIEN HELD BY (CREDITOR) The debtor, by counsel, asks the Court to avoid a judicial lien and states: 1. This Chapter 7 case was filed on , 20. 2. The debtor has a residence described as follows: [insert legal description] 3. On or about , 20, (creditor) obtained a judgment of $ against debtor. Creditor recorded a transcript of the judgment on , 20, with the County Clerk, in Book , Page , Doc. No. , creating a judicial lien on the debtor222s residence. 4. The fair market value of the residence is $ . Debtor's equity in the residence (apart from the judgment lien) is $ . 5. Debtor claimed his or her equity in the residence exempt under applicable law. 6. The judgment lien impairs the exemption and should be avoided under 247 522(f). 7. Concurrence in this motion was sought and not received WHEREFORE, debtor asks the Court to avoid the judicial lien against the residence. Signature Name: Address: Telephone: Email: American LegalNet, Inc. www.FormsWorkFlow.com -2- I certify that on , 20, I served this motion by first class mail, postage prepaid, on: [insert names, titles, addresses] And electronically on: [list] Signature American LegalNet, Inc. www.FormsWorkFlow.com