Local Rule RULE 4003-1: AVOIDANCE OF JUDICIAL LIEN
Bankr. D. Mass. — General rule
RULE 4003-1. AVOIDANCE OF JUDICIAL LIEN
(a) A motion to avoid a judicial lien pursuant to 11 U.S.C. § 522(f) shall:
(1) identify the holder of the judicial lien sought to be avoided and provide the name and address of the lien holder;
(2) state the date the judicial lien was granted and identify the court that issued the lien;
(3) state the amount of the judicial lien as of the date of the filing of the petition;
(4) identify the holders of all other liens on the property listed in order of their priority;
(5) state the amount of each other lien on the property and provide a total of same;
(6) state the amount of the exemption that is allegedly impaired and provide the applicable statute for the debtor's claim of exemption;
(7) state the value of the debtor's interest in the property and attach any available appraisal report;
(8) apply the formula under 11 U.S.C. § 522(f)(2)(A);
(9(8) state whether the debtor contends that the entire lien is voidable, or if the lien can only be partially avoided, the amount of the surviving lien; and
(10) 9) provide such documentary evidence as is necessary to establish the extent of the homestead declared.; and
(10) attach a completed Official Local Form 24 for avoidance of a judicial lien.
(b) Any opposition to a motion to avoid a judicial lien shall admit or deny each and every allegation of the motion, specifically state why the motion should not be granted, and apply the formula under 11 U.S.C. § 522(f)(2)(A). ). If the opposing party intends to rely on an appraisal report, the report shall be attached to the opposition.