UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF NEW YORK In re: ___________________________________, Case No.: __-_____ (rdd) Chapter 13 Debtor. ORDER GRANTING IN REM RELIEF FROM THE AUTOMATIC STAY AND DISMISSING CHAPTER 13 CASE Upon the motion (the "Motion") of __________________________ (with any subsequent successor or assign, the "Movant"), by its attorneys ____________________________________ ___________________________, (a) pursuant to 11 U.S.C. § 362(d)(1), from the automatic stay imposed in this case under 11 U.S.C. § 362(a) as to Movant's interest in real property commonly known as ________________________________ (the "Property"), and (b) pursuant to 11 U.S.C. § 362(d)(4)(B), for in rem relief from the automatic stay imposed in subsequent cases under 11 U.S.C. § 362(a), such that any and all future filings under the Bankruptcy Code during the next two years by the debtor herein, _______________________________ (the "Debtor"), non-debtor _________________________________, non-debtor _________________________, non-debtor _________________________________ or any other person or entity with an interest in the Property shall not operate as a stay as to Movant's enforcement of its rights in and to the Property; and, after due and sufficient service and notice, the Court having held a hearing on the Motion on __________, 20__; and no opposition having been submitted; and, after due deliberation, the Court having determined that the filing of the Debtor's bankruptcy petition was part of a scheme to delay, hinder, and defraud creditors that has involved multiple bankruptcy filings by the Debtor [and the Debtor’s family members] affecting the Property; and good and sufficient cause appearing, including the failure of the Debtor [or any of the Debtor’s family members] to perform American LegalNet, Inc. www.FormsWorkFlow.com their duties as debtors under the Bankruptcy Code in good faith in multiple bankruptcy cases affecting the Property, it is ORDERED that the automatic stay under 11 U.S.C. § 362(a) is vacated under 11 U.S.C. § 362(d)(1) as to Movant's interest in the Property, to permit Movant to pursue its rights in and remedies in and to the Property; and it is further ORDERED that, under 11 U.S.C. § 362(d)(4), and provided that this order is recorded in conformity therewith, this order terminating the automatic stay under 11 U.S.C. § 362(a) as to Movant's interest in the Property shall be binding in any other case filed under the Bankruptcy Code purporting to affect the Property that is filed not later than two years after the date of this order, such that the automatic stay under 11 U.S.C. § 362(a) shall not apply to Movant’s interest in the Property. Dated: _____________, New York ___________, 20___ Hon. Robert D. Drain U.S. Bankruptcy Court Judge 2 American LegalNet, Inc. www.FormsWorkFlow.com