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UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF OHIO WESTERN DIVISION AT DAYTON In re: Case No: Chapter 13 Judge: MOTION FOR SALE OF REAL ESTATE FREE AND CLEAR OF LIENS Now comes the above named Debtor(s) and moves this Court for an Order to sell the real estate located at:________________________free and clear of liens for a purchase price of $__________________. The funds received from the sale of real estate are to be disbursed as follows: 1. Lien holder ____________________ $_____________________ 2. Lien holder ____________________ $_____________________ 3. Real Estate Commission 4. Closing costs TOTAL DISBURSED $_____________________ $_____________________ $_____________________ The Debtor(s) has arranged the sale of real estate on short sale with ___________________________ accepting less than the balance on the mortgage(s). The realtor has agreed to accept less than the contract rate for his/her commission. Neither Debtor(s) nor the Chapter 13 Office will receive any funds from the sale of real estate. Wherefore, the Debtor(s) request an Order to Sell the Real Estate Free and Clear of Liens. Respectfully submitted: __________________________________ Attorney for Debtor(s) NOTICE OF FILING AND OPPORTUNITY TO OBJECT Debtor has filed a Motion for Sale of Real Estate Free and Clear of Liens with the Court. Your rights may be affected. You should read these papers carefully and discuss with your attorney, if you have one in this bankruptcy case. If you do not have an attorney, you may wish to consult one. If you do not want the Court to enter an order approving the Sale of Real Estate Free and Clear of Liens, then on or before twenty-one (21) days from the date listed on the Certificate of Service below, you or your attorney must file with the Court a written response explaining your position and/or a written request or a hearing. The Court must receive your response on or before the date above. You must also send a copy of your response on or before the date above. You must also send a copy of your response by the Court’s ECF system upon: Debtor’s Attorney Jeffrey M. Kellner, Chapter 13 Trustee U.S. Trustee, Columbus And on the following by ordinary U.S. mail addressed to: Debtor – Address If you or your attorney do not take these steps, the Court may decide that you do not oppose the relief sought in the motion and may enter an order granting the relief. CERTIFICATE OF SERVICE The undersigned hereby certifies that a copy of the foregoing Motion for Sale of Real Estate Free and Clear of Liens Combined with Notice of Filing and Opportunity to Object has been served upon the Chapter 13 Trustee and the United States Trustee by electronic filing in compliance with the ECF rules in place in this District, and upon the following by ordinary U.S. Mail, postage prepaid on this _______ day of ___________, 20___. __/s/__________________________________ Name of Attorney Names and Addresses of ALL parties. ###