court fillings. (motion to stay, notice of motion, certificate of service, draft. order, other documents needed for the draft motion)

April 21, 2023April 21, 2023 Discipline: Law
ASSIGNMENT EMAIL
To: The New paralegal
From: Thomas Hardy
Our client, MB FINANCIAL BANK has a mortgage on 1401-13 W. 127th Street, Calumet Park, Illinois. The property is owned by M&J Investment Group, LLC (the “Debtor”). We believe the property is worth only $1.8 million, and that the owners no longer have insurance on the property. The Debtor has defaulted on his mortgage and currently owes our client approximately $24,900 in unpaid mortgage payments. This Bankruptcy Case is set before Judge Barnes. Case No. 22-B-0001. It is a chapter 7 case. You will need to make sure you look up Judge Barnes Rules for filing motions which is on the bankruptcy website for the northern district of Illinois.

Please prepare: 

(i) a draft motion to lift stay; 
(ii) a notice of motion, 
(iii) a certificate of service, 
(iv) a draft order, and 
(v) any other documents that need to be filed with the draft motion. Remember Motions must be presented in the proper courtroom. 
Also, please prepare a cover memo telling me any fees are other related issues with filing the motion to lift stay. If there is information you do not have, please include it in the memo as information we need.

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