NM LF 4003-2 UNITED STATES BANKRUPTCY COURT DISTRICT OF NEW MEXICO In re: Case No. Debtor(s). MOTION TO AVOID (CREDITOR222S) LIEN ON HOUSEHOLD GOODS The debtor, by counsel, asks the Court to avoid a lien on the debtor's personal property pursuant to 11 U.S.C. 247 522(f) and states: 1. This Chapter 7 case was filed on , 20 . 2. On or about , 20, debtor borrowed about $ from (creditor). 3. As security for the debt debtor granted creditor a security interest in the following personal property held primarily for the personal, family, or household use of the debtor or the debtor222s dependents (the 223household goods224), all of which are now in debtor222s possession: [describe the household goods] 4. The debtor did not use any part of the borrowed money to buy the household goods. 5. Debtor's interest in the household goods is exempt. 6. Creditor222s lien impairs debtor222s exemption in the household goods and should be avoided under 11 U.S.C. 247 522(f). 7. Concurrence in this motion was sought and not received. WHEREFORE, debtor asks the Court to avoid creditor222s lien on the household goods. American LegalNet, Inc. www.FormsWorkFlow.com -2- Signature Name: Address: Telephone: Email: 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