XXX DISTRICT COURT
EASTERN DISTRICT OF XXX
……………………………………………………………………..X
In re:
Chapter 7
XXX, Case No.: XXX
Debtor.
……………………………………………………………………..X
XXX
Plaintiff,
v.
DARROW ARONOW, ESQ., HANIN R. SHADOOD, Adv. Pro. No: XXX
COURTNEY R. XXX, ESQ., FAY SERVICING
LLC, XXXX LOAN MANAGEMENT SERVICES,
INC., XXX, THE XXX
OF XXX, DOES 1-100 INCLUSIVE
Defendants.
……………………………………………………………………..X
NOTICE OF MOTION
To ALL Defendants and to ALL Attorneys of Record:
Please TAKE NOTICE that on August XXX, at XXX a.m. or soon thereafter, the
Plaintiff herein will move this Court for an Order to Withdraw or Dismiss Chapter 7
Bankruptcy, and for such other and further relief as this Court deems just and proper.
The Motion to Withdraw or Dismiss Chapter 7 Bankruptcy will be based on the grounds
that the Trustee has failed to protect Plaintiff or Plaintiff’s assets; and that there is just cause to
seek withdrawal of the case.
Further, the motion will be based on this Notice of Motion, the points, arguments, and
authorities in support of the Motion, on the records and file herein, and on such evidence as may
be presented at the hearing of the motion.
2
Respectfully submitted,
Date: _________________
XXX
Pro Se Debtor
3
CERTIFICATE OF SERVICE
I certify that a copy of this Motion for Reconsideration was served on [ENTER DATE] to the
Defendants in this action at the following addresses:XXX4
XXX
XXX
XXXX Loan Management Services, Inc.
DATE:
XXX
Pro Se Debtor
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