Fill and Sign the Bankruptcy Number Form

IN THE UNITED STATES BANKRUPTCY COURT FOR THE _____________ DISTRICT OF _____________ IN RE: CHAPTER 7 BANKRUPTCY NUMBER: _____________ ___________________________ MOVANT VS. MOTION NO. _____________ RESPONDENT(S) ___________________________, TRUSTEE RESPONDENT MOTION FOR RELIEF FROM AUTOMATIC STAY AND FOR ABANDONMENT COMES NOW, _____________ (hereinafter "Movant"), and moves the Court to enter an Order granting Movant relief from the automatic stay provisions of 11 U.S.C. § 362(a) of the Bankruptcy Code and for abandonment pursuant to §554(b) of the Bankruptcy Code and in support thereof would show unto this Court the following: 1. Movant holds a valid lien on the property of the Debtor(s) located at by virtue of Security Agreement dated _____________, on one (1) Mobile home Serial Number _____________ and described as _____________. Said Security Agreement is secured by a Note dated _____________ in the original principal amount of _____________. A copy of the Security Agreement and Note, which includes a description of the subject property, is attached hereto as Exhibit "A". 2. The Debtor(s) are in arrears for payments on said Security Agreement and Note for the months of _____________. The total amount due to Movant is approximately _____________ and the value of the property is _____________. There is no equity in the subject property for the benefit of the estate. 3. That since Debtor has not maintained the note payments as and when they have come due and there is no equity for the benefit of the estate, good cause exists to lift the automatic stay and allow Movant to commence foreclosure proceedings on said Deed of Trust. WHEREFORE, PREMISES CONSIDERED, Movant requests that the Trustee abandon the property from the estate pursuant to 11 U.S.C. § 554(b) and that the Court lift the automatic stay provisions of 11 U.S.C. § 362(a) of the Bankruptcy Code thereby allowing Movant to obtain possession of the Mobile Home, and that the Court enter an order awarding Movant attorney's fees and court costs. Respectfully submitted, BY:____________________________Its Attorney CERTIFICATE I, _____________ , do hereby certify that I have this date mailed via United States mail, postage pre-paid, a true and correct copy of the above and foregoing Motion for Relief from Automatic Stay to the following: Attorney for Debtor U.S. Trustee Debtor DATED this the _____________ day of _____________ , 20______. _____________________________