Free Motion to Avoid Household Goods Lien - West Virginia

UNITED STATES BANKRUPTCY COURT FOR THE SOUTHERN DISTRICT OF WEST VIRGINIA
In re Case Number

Debtor(s).

MOTION TO AVOID A NON-POSSESSORY, NON-PURCHASE MONEY SECURITY INTEREST
The Debtor (s) moves the Court to enter an order avoiding a lien which is a non-possessory, non-purchase money security interest in household goods and furnishings maintained by the Debtor(s) for personal and family use. The name and address of the creditor holding the non-possessory, non-purchase money security interest are listed below:

The Debtor(s) further represent that the security interest held by the above-named creditor impairs an exemption to which the Debtor(s) would be entitled under WV § 38-10-4. The property subject to the creditor's non-possessory, non-purchase money security interest is property of the type described under 11 U.S.C. § 522(f) and is listed below: __________________________________________________ __________________________________________________ __________________________________________________ __________________________________________________ The lien attached after ______day of _____________20___. The Debtor(s) requests that the Court enter an order avoiding the lien of the above-named creditor to the extent such lien impairs an exemption to which the Debtor(s) are entitled. Dated: _________________________________ Debtor _________________________________ Joint Debtor