Form B20A (Official Form 20A) (9/97) USBC, EDVA, Alexandria Division (12/01/09)

UNITED STATES BANKRUPTCY COURT

EASTERN DISTRICT OF VIRGINIA

Alexandria Division

In re: )

)

) Case No.

) Chapter

Debtor

NOTICE OF MOTION AND NOTICE OF HEARING

_____________________________ has filed papers with the court to ____________________

__________________________________________________________________________________.

Your rights may be affected. You should read these papers carefully and discuss them 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 wish the court to grant the relief sought in the motion, or if you want the court to

consider your views on the motion, then on or before ______________________, you or your attorney

must:

 Send to the parties listed below at least 14 days written notice of a hearing, which may be

set on any regularly-scheduled motion day of the judge assigned to the case. If necessary,

you may obtain a list of such dates by telephone from the clerk’s office. The original and

one copy of the notice must be filed with the clerk, accompanied by a motion day cover

sheet, a copy of which may be obtained from the clerk. If you are not represented by an

attorney, you may instead file with the clerk a written request for hearing. If you mail your

request for hearing to the court for filing, you must mail it early enough so the court will

receive it on or before the date stated above. The address of the clerk’s office is as follows:

Clerk of Court

United States Bankruptcy Court 

200 S. Washington Street

Alexandria, Virginia 22314

You will be notified by the clerk of the hearing date and will be responsible for sending

notice of hearing to the parties listed below.

 File with the court, at the address shown above, a written response with supporting

memorandum as required by Local Bankruptcy Rule 9013-1(H). Unless a written

response and supporting memorandum are filed and served by the date specified, the

Court may deem any opposition waived, treat the motion as conceded, and issue an

order granting the requested relief without further notice or hearing. If you mail your

response to the court for filing, you must mail it early enough so the court will receive it on

or before the date stated above. You must also mail a copy to the persons listed below.

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Form B20A (Official Form 20A) (9/97) Page 2 USBC, EDVA, Alexandria Division (12/01/09)

 Attend the hearing scheduled to be held on _____________________________ at

___________ o’clock ___.m. in Courtroom ______, United States Bankruptcy Court,

200 South Washington Street, Alexandria, Virginia 22314. If no timely response has

been filed opposing the relief requested, the court may grant the relief without

holding a hearing.

 A copy of any written response must be mailed to the following persons:

 ______________________________________

______________________________________

______________________________________

______________________________________

 ______________________________________

______________________________________

______________________________________

______________________________________

 United States Trustee, Region 4

115 South Union Street, Suite 210

Alexandria, VA 22314

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 or objection and may enter an order granting that relief.

Date: _______________________ Signature, name, address and telephone number

of person giving notice:

______________________________________

______________________________________

______________________________________

______________________________________

Virginia State Bar No. ___________________

Counsel for ____________________________

Certificate of Service

I hereby certify that I have this _____ day of __________________, , mailed or hand-delivered a 

true copy of the foregoing Notice of Hearing to the parties listed on the attached service list.

___________________________________

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U.S. BANKRUPTCY COURT

_______________ DISTRICT OF _______________

In Re: : Case No. _____________________ 

Debtor (s) __________________________________ : Chapter 7 (Judge _______________________ ) 

Creditor (s : MOTION FOR AUTHORITY TO REDEEM 

Address ___________________________________ : PERSONAL PROPERTY AND APPROVAL 

___________________________________ OF ASSOCIATED FINANCING AND 

___________________________________ : ATTORNEY FEES UNDER 11 U.S.C. 722

Now come (s) the Debtor (s) by and through counsel, and moves the court pursuant to 11 U.S.C. 722 and 

Bankruptcy Rule 6008 for a Redemption Order on the following grounds: 

1. The item to be redeemed is tangible personal property intended primarily for personal, family or household use

is more particularly described as follows:

Year _________ Make ________________ Model____________________ 

VIN # __ __ __ __ __ __ __ __ __ __ __ __ __ __ __ __ __ 

2. The interest of the Debtor (s) in such property is exempt or has been abandoned by the estate and the debt

(which is secured by said property to the extent of the allowed secured claim of the Creditor) is a dischargeable

consumer debt.

3. The allowed secured claim of said Creditor for purposes of redemption, the “redemption value”, should be

determined to be not more than $____________ as evidenced by the attached written appraisal.

4. Arrangements have been made by the Debtor (s) to pay to the said Creditor up to the aforesaid amount in a

lump sum should this motion be granted.

5. The payment for this proposed redemption is to be financed through Prizm Financial Co. LLC, with all of the

particulars of that financing (interest rate, finance charge, amount financed, total of payments, amount of

payments, etc.) set forth in full detail in the attachment(s) hereto. As demonstrated there, the monthly amount,

term of the payments and the overall amount of the repayment will be decreased significantly through the

proposed redemption. Moreover, the Debtor has agreed to borrow and disperse additional funds in the amount

of $__________, from their loan with Prizm Financial Co. LLC, for representation of the debtor(s) in securing 

for the benefit of the debtor(s) an order granting the debtor(s) the right to redeem under 11 U.S.C. 722 a certain 

motor vehicle, such compensation being in addition to that previously disclosed and being for services 

rendered beyond the scope of the legal services to have been rendered for such compensation heretofore 

disclosed.

WHEREFORE, the Debtor (s) request (s) the Court to order the said Creditor to accept from the Debtor (s) the 

lump sum payment of the redemption value and release their lien of record. In the event the said Creditor objects to 

this motion, the Debtor (s) requests the Court to determine the value of the property as of the time of the hearing on 

such objection. 

 __________________________________

Attorney for Debtor (s) 

NOTICE 

Notice is hereby given that unless an objection is made to this motion within 21 days following the date of service 

below, an order sustaining the motion may be granted by the Court. 

CERTIFICATE OF SERVICE 

I hereby certify that the foregoing has been served upon: the Creditor’s above noted, the U.S. Trustee, and the 

Chapter 7 Trustee by mailing a copy hereof by first class U.S. Mail on this _______ day of _________________, 

20_____. 

__________________________________

 Attorney for Debtor (s) 

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Owner Name: Clement Wiredu Prepared As Of:

11/8/2019 12:00:00

AM

Vehicle Description: 2013 Toyota Avalon Sedan 4D XLE V6

Year Make Model

4T1BK1EB5DU068985 97,767 Gray

Serial Number (VIN) Mileage Plate Color

No Yes No Yes No Yes

Cruise Control Leather Interior Radio

Theft Deterrent Manual Automatic

Power Windows Heated Seats 4WD/AWD

Power Seats Air Conditioning 3

rd Row Seating

Power Door Locks Power Sunroof Rear Entertainment

Other Items:

Good Fair Poor Good Fair Poor

Grill Left Fender

Front Bumper Left Door

Hood Left Quarter Panel

Right Fender Interior

Right Door Engine

Right Quarter Panel Brakes

Lights Paint Finish

Rear Bumper Tires

Roof

Comments

Hood, grill, trunk, rear bumper, driver's side doors and quarter panel, passenger's side quarter

panel and fender are scratched. Both bumpers are dented. Interior needs cleaning and

reconditioning. Four (4) tires need to be replaced.

Valuation Report: Based on Edmunds

Value

Average Base Value: $9,874.00

Mileage Class: Average:

Add-ons/Deducts:

Scratches $450.00

Dents $150.00

Interior $500.00

Tires (4) $500.00

Appraised Value: $8,274.00

The above vehicle condition report was prepared for the purpose of making a secured loan on said collateral. By signing below, preparer of report

certifies that information regarding collateral was ascertained via visual inspection or provided and collected in good faith from owner or owner’s

representative. Information as to vehicle’s condition has been applied with due diligence in conjunction with current publications by an

experienced valuation specialist. No other representations, direct or indirect, material or immaterial, are made, assured or implied by this report of

any other member of 722 staff or management.

/s/ Dan Hatfield

Collateral Valuation Services, LLC

P O Box 8361, Cincinnati, Ohio 45208

(513) 284-8539

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