motion approving reaffirm sample

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Attorney for Debtors/Movant

UNITED STATES BANKRUPTCY COURT

CENTRAL DISTRICT OF CALIFORNIA – RIVERSIDE DIVISION

IN RE

Debtors’ name

Debtors/Movant

)))))))))))))))

Chapter 7Case No.

MOTION FOR ORDER APPROVING REAFFIRMATION AGREEMENT BETWEEN DEBTORS AND SECURED CREDITOR FORD CREDIT.

Date: February ____, 2011Time: 01:30 pmLocation: 3420 Twelfth Street Riverside, CA 92501Courtroom: _____

TO THE HONORABLE ________________, UNITED STATES BANKRUPTCY JUDGE,

THE CHAPTER 7 TRUSTEE, AND ALL OTHER INTERESTED PARTIES:

Movant hereby request that the Court approve the Reaffirmation Agreement between the

above debtors and secured creditor _____________________ as follows:

1. A motion to reopen the case with the purpose to file a reaffirmation agreement

between the parties was granted on _______________, 2011. See Pacer

Document #___

2. The reaffirmation agreement between the parties was filed in Court on

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________________ . See Pacer Document #____

3. The parties, in this case the movant and secured creditor __________, have

reached an agreement to reaffirm the debt subject to Court approval of the agreement. A true and

correct copy of the Reaffirmation Agreement is marked as Exhibit “1” to this motion.

4. The agreement will not have any adverse impact on the debtor, estate, the Trustee,

or any other creditor in this bankruptcy case, and or any Discharge that the Movant may receive

in this case.

5. The parties believe that Court has the power and the authority to grant this motion

pursuant to 11 U.S.C. § 105 and that the agreement is in the best interests of both parties.

WHEREFORE, Movant requests that this motion be granted and the Court approve the

subject agreement, and for such other and further relief as the Court deems proper.

Dated: ___________________ Respectfully submitted,

By: . Attorney for Movant

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