Sample Motion to Avoid Judicial Lien

IN THE UNITED STATES BANKRUPTCY COURT
District
division

IN RE: §
§
Debtor § CASE NO.
Co debtor §
Debtor(s) §

DEBTOR’(S) MOTION TO AVOID JUDICIAL LIEN OF CREDITOR NAME

TO THE HONORABLE JUDGE OF SAID COURT:

COME NOW Debtor(s) in the above-captioned cause, and in support of this motion state that:

I.

Debtor(s) filed a voluntary petition for relief under 13 of Title 11 of the United States Code on 00/00/00.

II.

This motion is filed pursuant to 11 USC 522(f) to avoid and cancel a judicial lien held by CREDITOR NAME on real property used by Debtor(s) as their residence.

III.

CREDITOR NAME obtained a judgment against Debtor(s), cause no. 00-00000, In the County Court of Texas. CREDITOR NAME may have obtained a judicial lien on personal property claimed as exempt by Debtors.

IV.

Debtor(s) have elected to take the Federal Exemptions.

WHEREFORE, Debtor(s) pray for an order avoiding the judicial lien on Debtor’(s) residential real estate, if one exists, and for such additional or alternative relief as may be just and proper.

Respectfully submitted,

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