Local Rule Rule 4003-2: Lien Avoidance Under § 522(f).

Rule 4003-2. Lien Avoidance Under § 522(f).

(a) Judicial Liens on Real Property. If not made as part of a chapter 12 or 13 plan, a motion to avoid under § 522(f)(1)(A) a judicial lien on real property must be filed on LBF 717, and any proposed order must be lodged on LBF 717.07.

(b) Other Liens. A motion to avoid under § 522(f) a lien other than a judicial lien on real property, if not made as part of a chapter 12 or 13 plan, must be in writing and state—

(1) The name and address of the lienholder whose lien is to be avoided,

(2) The subsection of § 522(f) under which relief is requested,

(3) The nature of the lien to be avoided,

(4) The date upon which the lien was perfected,

(5) A description of the property sufficient for identification,

(6) The fair-market value of the property,

(7) A description of and the amounts due upon any security interests or other liens on the property,

(8) A description of the nature and amount of exemptions impaired by the lien to be avoided,

(9) The present balance owing on all security interests or liens on the property excluding any precomputed interest or other unearned charges,

(10) The extent to which the lien should be avoided, and

(11) Any other facts relevant to determining whether the motion should be granted.