I need a quote for a Motion for Relief From Stay in a scam involuntary Chapter 7 bankruptcy filing in Las Vegas that has implicated 5 different properties in California. The involuntary Ch. 7 BK filing is a carbon-copy of a prior filing in 12/2010 that was dismissed on 2/23/2011 for failure to appear at an OSC.
The recent 8/15/12 "involuntary" Ch. 7 was filed by the same purported petitioning creditors as the 12/10 petition and identifies 8 separate "akas" and indicates the SSN of the debtor as "unknown". This is a sham filing designed to buy the occupants more time in the property for free.
My client is the owner of one of the five properties implicated in the recent Ch. 7 filing and the Sheriff's Office has stated that since it is an "involuntary" petition that they will not effect a lock-out today as was scheduled even though it was filed post-UD judgment.
I cannot file the MFRS because I am not licensed to practice in Nevada federal court. This should be an easy "cut & paste" job. My client is resigned to the fact that he will have to wait at least 2 weeks before we can get the occupants locked out and the property placed on the market for sale.
I need a firm price quote by someone who knows what they are doing. Please advise accordingly. I want this done ASAP.
1 Answer from Attorneys
A firm quote may be difficult to provide as the attorney providing it would have no way of knowing how much work might be involved. Please see In re Taub, 439 B.R. 261 (2010) for a basic outline of the process.
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