LIEN AVOIDANCE MOTIONS

(a)
Requirements Any debtor seeking to avoid a lien pursuant to either 11 U.S.C. §§ 522(f) or 1322(b) shall file a separate written motion as to each alleged lien holder. The motion shall identify (a) the lien to be avoided and its amount; (b) the amount, listed separately, of all other liens on the property; (c) if applicable, the amount of the impaired exemption; and (d) the value of the subject collateral. Motions to avoid judicial liens shall also include the case number and the court where the underlying judgment was entered and list the common address of any real property affected by the lien. A sample notice and motion are available at www.insb.uscourts.gov .
(b)
Nonpossessory, Nonpurchase Money Security Interests in Household Goods Motions to avoid a nonpossessory, nonpurchase money security interest in household goods under 11 U.S.C. § 522(f)(1)(B) must, in addition to the requirements in paragraph (a), specifically identify the household goods that are subject to the security interest sought to be avoided, referring to the definition of “household goods” provided in 11 U.S.C. § 522(f)(4).
(c)
Service
The debtor shall serve the motion and notice thereof on the lien holder, or on the attorney for the lien holder but only if such attorney has appeared in the bankruptcy case on behalf of the lien holder, and all other parties in interest. The notice shall allow at least twenty

(20) days from the date of service to file objections.

(d) Filing and Certificate of Service

Along with the motion the debtor shall file with the Court a copy of the notice and a certificate of service in compliance with S.D.Ind. B-9013-2.