Motion For Relief From Automatic Stay To Negotiate Mortgage Loan Modification

UNITED STATES BANKRUPTCY COURT EASTERN DISTRICT OF MISSOURI EASTERN DIVISION In re ____________________, Debtor(s). ) ) ) ) ) Case No. _________________ Chapter 13 MOTION FOR RELIEF FROM AUTOMATIC STAY TO NEGOTIATE MORTGAGE LOAN MODIFICATION The Debtor(s), _______________, file this Motion for Relief from Automatic Stay to Negotiate Mortgage Loan Modification (the "Motion"), and, in support thereof, would show the Court the following. 1. The Court has jurisdiction of this Motion pursuant to 28 U.S.C. §§ 157(a) and 1334(a) and Local Rule 9.01(B)(1) of the United States District Court for the Eastern District of Missouri. This is a core proceeding pursuant to 28 U.S.C. § 157(b)(2)(G). The Debtor(s) seek to conduct negotiations with the Debtor's(s') current mortgage lender, ____________ (the "Lender"), in an attempt to reach agreement on a modification of the loan secured by the Debtor's(s') residential real estate located at _____________, MO 63___ (the "Loan"). The Debtor(s) request that the automatic stay of 11 U.S.C. §362(a) (the "Automatic Stay") be lifted for the limited purpose of allowing Loan modification negotiations with the Lender to take place. Should the Debtor(s) and the Lender reach an agreement on a Loan modification, the Debtor(s) will seek further relief from the Automatic Stay so that the Debtor(s) and the Lender may enter into the Loan modification. Such relief will be requested on no less than 10 days notice to the Chapter 13 Trustee. 2. 3. 4. WHEREFORE, premises considered, the Debtor(s) request that the Court grant the relief requested in this Motion and any other such relief to which the Debtor(s) may be entitled. Respectfully Submitted, _____________________________ (Debtor or attorney signature block) American LegalNet, Inc. www.FormsWorkflow.com CERTIFICATE OF SERVICE (Debtor(s) add certificate of service.) Page 2 of 2 American LegalNet, Inc. www.FormsWorkflow.com