Legal Motion to Approve

MOTION TO APPROVE

Court:    County:

Case No.:    Judge:

Movant Name:    Respondent Name:

RECITALS

WHEREAS, Movant has entered into certain agreements and made proposals described below that require entry of an order by this Court approving the transactions and terms set forth herein; and

WHEREAS, the parties have conferred and reached terms for resolution, disposition, or authorization of the subject matter, and Movant seeks judicial approval to effectuate the same consistent with applicable procedural and substantive law; and

WHEREAS, good cause exists to grant the relief requested because the proposed disposition is fair, reasonable, and in the interests of justice as more fully set forth below.

NOW, THEREFORE

Movant hereby moves the Court for an order approving the matters described in this Motion and requests that the Court grant the relief set forth in the Requested Relief section below.

1. BACKGROUND

The material facts supporting this Motion are as follows:

2. AUTHORITY

This Court has jurisdiction to decide this Motion and to grant the relief requested pursuant to the court's statutory and inherent authority and the applicable rules of civil procedure. Movant relies on the Court's power to approve settlements, transactions, and other disputed matters where the Court finds that the proposed action is fair, reasonable, and consistent with law. Movant further asserts that procedural requirements for notice and opportunity to object have been satisfied or will be satisfied as described below.

3. REQUESTED RELIEF

Movant respectfully requests that the Court enter an order that:

Approves the settlement or compromise described in Exhibit A and authorizes the parties to perform thereunder.
Authorizes distribution of proceeds or funds in accordance with the terms set forth in Exhibit B.
Approves the payment of fees, costs, and expenses as detailed in Exhibit C.
Authorizes sale or transfer of specified assets described in Exhibit D, free and clear of liens as provided in the proposed order.

Additional requested relief or special conditions:

4. NOTICE AND SERVICE

Movant certifies that notice of this Motion has been provided to interested parties in accordance with governing rules and orders of the Court. The method of service and the parties served are as follows:

Certification of service: Movant declares under penalty of perjury that the foregoing is true and correct and that service was completed in the manner described on the date(s) indicated below.

Date of Service:

5. EXHIBITS

The following documents are attached as exhibits in support of this Motion:

6. CONCLUSION & PRAYER FOR RELIEF

For the foregoing reasons, Movant respectfully requests that the Court enter an order:

(a) granting this Motion in its entirety; (b) approving the settlement, distributions, fees, and other actions identified herein and in the attached exhibits; (c) authorizing the parties and their counsel to implement and perform under the approved terms; and (d) granting any further relief the Court deems just and proper.

GOVERNING LAW; MISCELLANEOUS

Governing Law: This Motion and any order entered hereunder shall be governed by and construed in accordance with the substantive law of the jurisdiction in which the Court presides, without regard to any conflict-of-law principles that would require the application of another jurisdiction's law.

Entire Agreement: The documents and representations incorporated into this Motion constitute the entire understanding between the parties with respect to the subject matter of this Motion and supersede all prior negotiations and agreements, whether oral or written, to the extent relevant to the matters presented here.

Severability: If any provision of an order granting this Motion or of the Motion itself is held to be invalid, illegal, or unenforceable, such invalidity, illegality, or unenforceability shall not affect any other provision of the order or the Motion, which shall remain in full force and effect.

Amendments and Waiver: This Motion may be amended or supplemented by written filings as necessary. No waiver of any provision of an order entered in connection with this Motion shall be effective unless in writing and signed by the waiving party.

CERTIFICATION

I certify under penalty of perjury that the information contained in this Motion is true and correct to the best of my knowledge, information and belief, and that I am authorized to submit this Motion on behalf of the Movant.

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