Lien Avoidance

(a) Motion. Any motion seeking to avoid a lien pursuant to 11 U.S.C. § 522(f) shall be substantially in the form of LBF 4003-2A. (b) Multiple Liens. If a debtor moves to avoid multiple liens on the same property pursuant to 11 U.S.C. § 522(f)(2), the debtor shall file one motion seeking to avoid each lien in ascending order of priority (i.e., the impairment calculation must avoid the most junior lien first).

If the debtor has previously avoided a lien against the property, the impairment calculation shall omit the amount of each lien that was previously so avoided. (c) Service. The movant shall ensure that the motion is served in accordance with Bankruptcy Rule 7004, made applicable by Bankruptcy Rule 9014(b). In order to be valid, service must be made at least twenty-one (21) days prior to the hearing.