Local Rule 4003-2: Lien Avoidance
Bankr. M.D. Tenn. — General rule
4003-2 Lien Avoidance
(a) Motion. Except when provided for in a Chapter 13 Plan, a motion to avoid a lien under 11 U.S.C. § 522(f) must provide:
(1) the identity of the creditor whose lien is to be avoided—the creditor shall be listed in the title of the motion;
(2) a description of the property subject to the lien;
(3) the balance of debt secured by the creditor's lien;
(4) the fair market value of the property;
(5) the identity of any other holder of a lien encumbering the property and the amount due on such lien;
(6) the specific statutory authority for the claimed exemption; and
(7) the amount claimed exempt.
(b) Procedure. Movant shall comply with the LBR 9013-1 Motion Practice Procedures.
(c) Order. A motion to avoid a lien under 11 U.S.C. § 522(f) must be accompanied by a proposed order form located at the court's website at https://www.tnmb.uscourts.gov/forms/all-forms/local_bankruptcy_forms.