KLEIN LAW GROUP, P.A. Page 1 of 2 

4800 N. FEDERAL HWY., SUITE B-307, BOCA RATON, FLORIDA 33431 

TEL:(561) 353-2800  FAX:(561) 353-1250  EMAIL: ENK@KLEINATTORNEYS.COM

UNITED STATES BANKRUPTCY COURT 

SOUTHERN DISTRICT OF FLORIDA 

www.flsb.uscourts.gov

IN RE: 

PAUL IRA TELVI and 

FRANCES LINDA TELVI 

 Debtor. 

Case No.: 20-14947-MAM 

Chapter: 7 

 

DEBTORS’ MOTION FOR AUTHORITY TO REDEEM PERSONAL PROPERTY AND 

APPROVAL OF ASSOCIATED FINANCING AND ATTORNEY FEES 

COMES NOW, the Debtors, PAUL IRA TELVI and FRANCES LINDA TELVI

(“DEBTOR”), by and through undersigned counsel, pursuant to 11 U.S.C. §722 and Bankruptcy 

Rule 6008, moves this Court for a redemption order, and in support thereof state as follows: 

1. Debtors filed for relief under Chapter 7 of title 11 U.S.C. on April 30, 2020. A meeting 

of creditors is scheduled for May 28, 2020. 

2. The item to be redeemed is tangible personal property intended primarily for person, 

family, or household use, and is more particularly described as: 

Cadillac SRX (2011) 

VIN - 3GYFNAEY8BS518119 

(“PROPERTY”). The creditor, PNC Bank (“CREDITOR”), holds a lien on the Property. 

3. The interest of Debtor in the Property is exempt or has been abandoned by the estate and 

the debt (which is secured by the property to the extent of an allowed secured claim of the Creditor) 

is a dischargeable consumer debt. 

4. The allowed secured claim of the Creditor for the purposes of redemption, the 

“redemption value”, should be determined to be no more than $7,800.00 as evidenced by the 

attached written appraisal. 

Case 20-14947-MAM Doc 13 Filed 05/21/20 Page 1 of 8
KLEIN LAW GROUP, P.A. Page 2 of 2 

4800 N. FEDERAL HWY., SUITE B-307, BOCA RATON, FLORIDA 33431 

TEL:(561) 353-2800  FAX:(561) 353-1250  EMAIL: ENK@KLEINATTORNEYS.COM

5. Arrangements have been made by Debtor to pay Creditor up to the aforesaid amount in a 

lump sum should this motion be granted. The payment for the 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 payments, amount of payments, etc.) set forth in full detail in the 

attachments hereto. As demonstrated, the monthly amount, terms of payment, and overall amount of 

the repayment will be decreased significantly through the proposed redemption. Moreover, Debtor 

has agreed to borrow and disperse additional funds on the amount of $700.00, from their loan with 

Prizm Financial Co. LLC, for the undersigned’s representation to obtain an order allowing 

redemption under 11 U.S.C. §722 of the Property, such compensation being in addition to that 

previously disclosed. 

WHEREFORE, Debtor respectfully requests this Court enter an order requiring Creditor 

accept the lump sum payment of the redemption value of the Property and release their lien of 

record. If Creditor objects to the motion, then Debtor requests this Court determine the value of the 

Property as of the time of the hearing on such objection. 

I HEREBY CERTIFY that I am admitted to the Bar of the United States District Court for 

the Southern District of Florida and I am in compliance with additional qualifications to practice in 

the Court set forth in Local Rule 2090-1(A). 

Respectfully submitted, 

 KLEIN LAW GROUP, PA 

 4800 N. Federal Hwy., Suite B-307 

 Boca Raton, Florida 33431 

 Tel: (561) 353.2800 

 Fax: (561) 353.1250 

 Email: enk@kleinattorneys.com 

 Attorney for Debtors 

 By: /s/ Eric Klein____________ 

 Eric N. Klein 

 Florida Bar No.: 0035985

Case 20-14947-MAM Doc 13 Filed 05/21/20 Page 2 of 8
LOAN DISCLOSURE, NOTE AND

SECURITY AGREEMENT

Account No: 

Loan Amount: $8,719.75

Loan Date: 

Paul Telvi and Fran Telvi

9730 Boca Gardens Parkway, Unit C

Boca Raton, Florida 33496

Name / Address of Borrower(s)

“You” and “Your” refer to each Borrower

above, jointly and severally.

722 Redemption Funding, Inc.

3700B Park 42 Dr., Suite 150A

Cincinnati, Ohio 45241

“We”, “us” and “our” refer to the Lender

above, its successors and assigns.

Federal Truth-In-Lending Disclosure:

ANNUAL PERCENTAGE RATE

(APR) - The cost of your credit as

a yearly rate.

22.559%

FINANCE CHARGE - The dollar

amount the credit will cost you.

$3,963.75

AMOUNT FINANCED - The

amount of the credit provided to

you or on your behalf.

$8,709.75

TOTAL OF PAYMENTS - The

amount you will have paid after you

have made all payments as

scheduled.

$12,673.50

Your Payment

Schedule will be:

Number of Payments:

42

Amount of Payments:

$301.75

When Payments are Due:

On the ______ day of each month beginning

____/_____/_____

Security: You are giving a security interest in your automobile or mobile home specifically described below.

Late Charge: You will be charged five percent (5.0%) of the full amount of a scheduled payment or $15.00, which ever is greater, as a late

charge on any installment not paid in full within ten (10) days after its due date.

Prepayment: If you pay off this loan early, you will not have to pay an early payment penalty.

Note Document: See your contract documents for any additional information about nonpayment, default, any required repayment in full before 

the scheduled date, and prepayment refunds and penalties.

Collateral Description:

Year Make Model Color Serial Number

2011 Cadillac SRX-V6 Red 3GYFNAEY8BS518119

PROMISE TO PAY: You, jointly and severally, promise to pay

to our order the amount equal to the PRINCIPAL AMOUNT OF

LOAN listed as Item (J) under ITEMIZATION OF AMOUNT

FINANCED plus interest on such unpaid balance at the

CONTRACT RATE OF INTEREST specified under

ITEMIZATION OF AMOUNT FINANCED. The actual Finance

Charge will be computed on unpaid principal balances

outstanding from time to time, for the time outstanding (in

accordance with section 1321.57(C)(1)(a) of Ohio Revised Code),

together with such other charges as permitted under O.R.C.

1321.57 and agreed to in this Loan Disclosure, Note, and Security

Agreement.

The payment amount of each installment specified above was

calculated utilizing the Contract Rate of Interest and Principal

Amount of Loan using a regular amortization schedule for the

term of this loan. The Contract Rate of Interest and the Annual

Percentage Rate may not be equal as a result of the classification

as finance charges under Regulation Z of the federal Truth-inLending Act of certain charges that would not be so classified

under O.R.C. 1321.51 to 1321.60. Similarly, the Amount Financed

may not be equal to the Principal Amount of Loan as a result of

such classifications.

COLLATERAL: To secure repayment of this loan, you grant

to us a security interest in: 1) the motor vehicle/personal

property listed above, complete with attachments, accessories

and equipment including all additions and accessions thereto,

replacements and substitutions thereof, whether in whole or in

part and whenever acquired, and 2) all proceeds, from insurance

or otherwise, arising from any disposition thereof (said security

interest hereinafter called "Collateral"). Collateral is intended to

secure payment of the indebtedness described above, together

with delinquency charges as provided and, in the event of default,

amounts actually expended for costs and disbursements incurred

in legal proceedings to collect the loan or to realize on any

security, to the extent permitted by applicable law.

FINANCE CHARGE: The Finance Charge consists of interest,

origination and credit investigation charges. The Finance Charge

disclosed above is computed on outstanding unpaid principal

balances on the basis that installments shall have been paid

according to contract. Delinquency will increase the Finance

Charge as the contract rate is computed on actual unpaid

balances of amount financed for the actual time outstanding.

APPLICABLE LAW: The laws of the State of Ohio will govern this

note and any agreement securing this note. The federal Truth-InLending disclosures on the front page hereof are disclosures only

and are not intended to be terms of this agreement unless

expressly referred thereto herein. The fact that any part of this

note cannot be enforced will not affect the rest of this note. Any

change to this note or any agreement securing this note must be

in writing and signed by you and us.

ITEMIZATION OF AMOUNT FINANCED

Amounts disbursed on your behalf:

Attorney Fee Escrow Account: $700.00 (A)

PNC Bank $7,800.00 (B)

(C)

 Appraisal Fee to:

Collateral Valuation Services $0.00 (D)

Single Interest Insurance Premium to:

Valley National Insurance $135.00 (E)

Service Contract to:

N/A (F)

Lien recording costs, etc. $74.75 (G)

Loan origination charge* $0.00 (H)

Credit investigation charge* $10.00 ( I )

PRINICIPAL AMOUNT OF LOAN

(Sum of A through I) $8,719.75 (J)

Prepaid finance charges $10.00 (K)

AMOUNT FINANCED (J minus K) $8,709.75 (L)

*Payable to 722 Redemption Funding, Inc.

CONTRACT RATE OF INTEREST 22.49%

PREPAYMENT: You may prepay this loan in whole or in part at any time. If you

prepay in part, you must still make each later payment in the original amount as

it becomes due until this note is paid in full.

LENDER’S SINGLE INTEREST INSURANCE, if written in connection with this

loan, may be obtained from any person of your choice that is acceptable to us. 

If you desire that this insurance be obtained through us, the cost is set forth in

the ITEMIZATION OF AMOUNT FINANCED.

DEFAULT CHARGES AND RETURNED CHECK FEES: We may collect a

default charge (also known as a “Late Charge”). The amount of the Late

Charge shall be in accordance with the block indicated above for each full

month that any installment is outstanding after the due date of such installment

scheduled by the contract. We may collect a Late Charge for one full month for

any installment that is past due more than ten (10) days. We may also charge

and receive check collection charges not greater than twenty dollars ($20.00)

plus any amount passed on from other financial institutions for each check,

negotiable order of withdrawal, share draft, or other negotiable instrument

returned or dishonored for any reason. Late Charges and returned check fees

may be collected at the time they accrue or any time thereafter.

(Continued on back)

POWER OF ATTORNEY

To facilitate your grant of a security interest in the Collateral, you irrevocably constitute and appoint us to be your attorney-infact to perfect our lien with regard to the Collateral and to do such other acts as necessary or convenient thereto.

By signing below you agree, jointly and severally, to the terms and conditions set forth on the face and reverse of this

document and acknowledge receipt of a fully completed copy.

NOTICE TO BORROWER(S): DO NOT SIGN THIS LOAN DISCLOSURE, NOTE, AND SECURITY AGREEMENT BEFORE YOU

READ IT (FRONT AND BACK) OR IF IT CONTAINS ANY BLANK SPACES. YOU ARE ENTITLED TO AN EXACT COPY OF THE

DOCUMENT YOU SIGN. THIS LOAN IS MADE UNDER THE AUTHORITY OF O.R.C. 1321.51 TO 1321.60.

________________________________________________________ ________________________________________________________

SIGNATURE OF BORROWER SIGNATURE OF CO-BORROWER

Case 20-14947-MAM Doc 13 Filed 05/21/20 Page 3 of 8
ADDITIONAL TERMS AND CONDITIONS

(Continued from front page)

USURY: The interest rate and other charges on this loan will never

exceed the highest rate or charge allowed by applicable law for this

loan.

POST-MATURITY INTEREST: Interest will accrue on the principal

balance remaining unpaid after final maturity at the Contract Rate of

Interest specified on the front page hereof. For purposes of this

section, final maturity occurs:

(a) If the note is payable on demand, on the date we make demand

for payment;

(b) If the note is payable on demand with alternative payment

date(s), on the date we make demand for payment or on the

final alternative payment date, whichever is earlier;

(c) On the date of the last scheduled payment of principal; or

(d) On the date we accelerate the due date of this loan (demand

immediate payment).

REAL ESTATE OR RESIDENCE SECURITY: If this loan is secured

by real estate or a residence which is personal property, the existence

of a default and our remedies for such a default will be determined by

applicable law, by the terms of any separate instrument creating the

security interest and, to the extent not prohibited by law and not

contrary to the terms of any such separate instrument creating the

security interest, by this agreement.

DEFAULT: Subject to any limitations in the “REAL ESTATE OR

RESIDENCE SECURITY” paragraph above, you will be in default on

this loan and any agreement securing this loan if any one or more of

the following occurs:

(a) You fail to make a payment in full when due;

(b) You die, are declared incompetent, or become insolvent;

(c) You fail to keep any promise you have made in connection with

this loan;

(d) You make any written statement or provide any financial

information that is untrue or inaccurate at the time it is provided;

(e) The Collateral securing the loan is damaged, destroyed, seized

or stolen;

(f) You fail to provided any additional security we may require; or

(g) Anything else happens that causes us to believe we will have a

difficult time collecting the amount you owe us.

If any of you are in default on this note or any security agreement,

we may exercise our remedies against any or all of you.

REMEDIES: Subject to any limitation in the “REAL ESTATE OR

RESIDENCE SECURITY” paragraph above, if you are in default on

this loan or any agreement securing this loan, we may:

(a) Cause unpaid principal, earned interest and all other agreed

charges you owe us under the loan to be immediately due;

(b) Use the right of set-off as explained below;

(c) Demand more security or new parties obligated to pay this loan

(or both) in return for not using any other remedy;

(d) Make a claim for any and all insurance benefits or refunds that

may be available on your default;

(e) Pay taxes or other charges, or purchase any required

insurance, if you fail to do these things (but we are not required

to do so). We may add the amount we pay to this loan and

accrue interest on that amount at the interest rate disclosed on

page 1 until paid in full:

(f) Require you to gather the Collateral and any related records

and make it available to us in a reasonable fashion;

(g) Take immediate possession of the Collateral, but in doing so we

may not breach the peace or unlawfully enter onto your

premises. We may sell, lease or dispose of the Collateral as

provided by law. (If the Collateral includes a manufactured

home, we will begin the repossession by giving you an

opportunity to cure your default, as required by law.) We may

apply what we receive from the sale of the Collateral to our

expenses and then to the debt. If what we receive from the

sale of the Collateral is less than what you owe us, we may take

you to court to recover the difference; and

(h) Use any remedy we have under applicable state or federal law.

You agree that when we must give notice to you of our intended

sale or disposition of the Collateral, the notice is reasonable if it is sent

to you at your last known address by first class mail 10 days before the

intended sale or disposition. You agree to inform us in writing of any

change in your address.

By choosing any one or more of these remedies we do not give up

our right to use another remedy later. By deciding not to use any

remedy should you be in default, we do not give up our right to

consider the event a default if it happens again.

If any of you are in default on this note or any security agreement,

we may exercise our remedies against any or all of you.

COSTS OF COLLECTION: You agree to pay us all costs and

disbursements to which we may become entitled by law in connection

with any suit to collect this loan or any lawful activity to realize on any

security after default. This provision also shall apply if you file a

petition or any other claim for relief under any bankruptcy rule or law of

the United States, or if another files such petition or other claim for

relief against you.

SET-OFF: You agree that we may set off any amount due and

payable under this note against any right you have to receive money

from us. “Right to receive money from us” means:

(a) Any deposit account balance you have with us;

(b) Any money owed to you on an item presented to us or in our

possession for collection or exchange; and

(c) Any repurchase agreement or other non-deposit obligation.

“Any amount due and payable under this note” means the total

amount of which we are entitled to demand payment under the terms

of this note at the time we set off. This total includes any balance the

due date for which we properly accelerate under this note.

If your right to receive money from us is also owned by someone

who has not agreed to pay this note, our right of set-off applies to your

interest in the obligation and to any other amounts you could withdraw

on your sole request or endorsement. Our right of set-off does not

apply to an account or other obligation where your rights arise only in a

representative capacity. It also does not apply to any Individual

Retirement Account or other tax-deferred retirement account.

We will not be liable for the dishonor of any check when the

dishonor occurs because we set off this debt against any of your

accounts. You agree to hold us harmless from any such claims arising

as a result of our exercise of our right of set-off.

OTHER SECURITY: Any present or future agreement securing any

other debt you owe us also will secure the payment of this loan. 

Property securing another debt will not secure this loan if such property

is your principal dwelling and we fail to provide any required notice of

right of rescission.

OBLIGATIONS INDEPENDENT: You understand that your obligation

to pay this loan is independent of the obligation of any other person

who has also agreed to pay it. We may, without notice, release you or

any of you, give up any right we may have against any of you, extend

new credit to any of you, or renew or change this note one or more

times and for any term, and you will still be obligated to pay this loan. 

We may, without notice, fail to perfect our security interest in, impair, or

release any security and you will still be obligated to pay this loan.

WAIVER: You waive (to the extent permitted by law) demand,

presentment, protest, notice of dishonor and notice of protest.

PRIVACY: You agree that from time to time we may receive credit

information about you from others, including other lenders and credit

reporting agencies. You agree that we may furnish on a regular basis

credit and experience Information regarding your loan to others

seeking such information. To the extent permitted by law, you agree

that we will not be liable for any claim arising from the use of

information provided to us by others or for providing such Information

to others.

FINANCIAL STATEMENTS: You will give us any financial statements

or information that we feel is necessary. All financial statements and

information you give us will be correct and complete.

PURCHASE MONEY LOAN: If this is a Purchase Money Loan, we

may include the name of the seller on the check or draft for this loan. 

Purchase Money Loan means any loan the proceeds of which, in

whole or in part, are used to acquire any property securing the loan

and all extensions, renewals, consolidations and refinancings of such

loan.

SECURED OBLIGATIONS: This agreement secures this loan

(including all extensions, renewals, refinancings and modifications) and

any other debt you have with us now or later. Collateral described in

this agreement will not secure other such debts if we fail to give any

required notice of the right of rescission with respect to the Collateral. 

Also, this agreement will not secure other debts if this security interest

is in household goods and the other debt is a consumer loan. This

agreement will last until it is discharged in writing.

OWNERSHIP AND DUTIES TOWARD PROPERTY: Unless a coowner(s) of the Collateral signed a third party agreement, you

represent that you own all the Collateral. You will defend the Collateral

against any other claim. You agree to do whatever we require to

perfect our interest and keep our priority. You will not do anything to

harm our position.

You will keep the Collateral in your possession (except if pledged

and delivered to us). You will keep it at your address unless we agree

otherwise in writing.

You will not try to sell or transfer the Collateral, or permit the

Collateral to become attached to any real estate, without our written

consent. You will pay all taxes and charges on the Collateral as they

become due. You will inform us of any loss or damage to the

Collateral. We have the right of reasonable access in order to inspect

the Collateral. If the Collateral is a motor vehicle, you represent that it

is not a vehicle seized pursuant to any federal, state or local forfeiture

law.

INSURANCE: You agree to buy insurance on the Collateral against

the risks and for the amounts we require from a provider reasonably

acceptable to us. You will name us as loss payee on any such policy.

You will keep the insurance until all debts secured by this agreement

are paid. We may require added security on this loan if we agree that

insurance proceeds may be used to repair or replace the Collateral.

You agree that if the insurance proceeds do not cover the amounts you

still owe us, you will pay the difference.

FILING: A copy of this agreement may be used as a financing

statement when allowed by law.

ASSUMPTIONS: This security agreement and any loan it secures

cannot be assumed by someone buying the Collateral from you. This

will be true unless we agree in writing to the contrary. Without such an

agreement, if you try to transfer any interest in the Collateral, you will

be in default on all obligations that are secured by this security

agreement.

The following notice applies only if the proceeds of this loan have

been applied in whole or substantial part to the purchase of goods

and/or services from a person who, in the ordinary course of business

sells goods and/or services to consumers, and Borrower has been

referred to the Lender by the Seller, or Lender is affiliated with the

Seller by common control, contract, or business arrangement.

NOTICE: ANY HOLDER OF THIS CONSUMER CREDIT

CONTRACT IS SUBJECT TO ALL CLAIMS AND DEFENSES

WHICH THE DEBTOR COULD ASSERT AGAINST THE SELLER OF

GOODS OR SERVICES OBTAINED WITH THE PROCEEDS

HEREOF. RECOVERY HEREUNDER BY THE DEBTOR SHALL

NOT EXCEED AMOUNTS PAID BY THE DEBTOR HEREUNDER.

(Page 2 of 2)

Case 20-14947-MAM Doc 13 Filed 05/21/20 Page 4 of 8
Redemption vs. Reaffirmation Savings Analysis

Date of Valuation: 05/21/2020

Debtor(s): Paul Telvi

Vehicle: 2011 Cadillac SRX-V6 Utility 4D Luxury 2WD

Current Lienholder: PNC Bank

Reaffirmation Redemption

Value $7,800.00

Payment $452.00 $301.75

Term 42 42

Total $18,984.00 $12,673.50

Savings $6,310.50

* Above good faith estimates are inclusive of all fees. Payments may vary

based on included legal fees set by individual attorneys. Payments were

calculated using a contract rate of 22.49%.

** Please call for settlements outside pre-approved range.

Phone (513) 721-2800 Fax (513) 721-2822  3700B Park 42 Dr, Suite 150A  Cincinnati, OH 45241

Case 20-14947-MAM Doc 13 Filed 05/21/20 Page 5 of 8
Owner Name: Paul Telvi and Fran Telvi Prepared As Of:

5/20/2020 12:00:00

AM

Vehicle Description: 2011 Cadillac SRX-V6 Utility 4D Luxury 2WD

Year Make Model

3GYFNAEY8BS518119 57,001 Red

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 Interior needs cleaning and reconditioning. Brakes need to be replaced.

Valuation Report: Based on Edmunds Retail

Value

Average Base Value: $8,995.00

Mileage Class: Average:

Add-ons/Deducts:

Interior Reconditioning -$500.00

Replace Brakes -$300.00

-$395.00

-

-

Appraised Value: $7,800.00

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/ Stephanie Smith

Collateral Valuation Services, LLC

P O Box 8361, Cincinnati, Ohio 45208

(513) 284-8539

Case 20-14947-MAM Doc 13 Filed 05/21/20 Page 6 of 8
 

UNITED STATES BANKRUPTCY COURT 

SOUTHERN DISTRICT OF FLORIDA 

www.flsb.uscourts.gov

IN RE: 

PAUL IRA TELVI and 

FRANCES LINDA TELVI 

 Debtor. 

Case No.: 20-14947-MAM 

Chapter: 7 

 

ORDER GRANTING DEBTOR’S MOTION FOR AUTHORITY TO REDEEM 

PERSONAL PROPERTY AND APPROVAL OF ASSOCIATED FINANCING AND 

ATTORNEY FEES 

THIS CAUSE, having come before the court on __________ upon Debtor’s Motion for 

Authority to Redeem Personal Property and Approval of Associated Financing and Attorney 

Fees [E.C.F. ____] without objection, the Court finds as follows: 

A. The tangible personal property described below is intended primarily for personal, 

family, or household use of the Debtor: 

Cadillac SRX (2011) 

VIN - 3GYFNAEY8BS518119 

B. The debt owed to Creditor is a dischargeable consumer debt and the Debtor’s interest in 

Case 20-14947-MAM Doc 13 Filed 05/21/20 Page 7 of 8
such property is exempt or has been abandoned by the estate. 

C. The value of the secured claim of the Creditor for redemption purposes, the “redemption 

amount” is $7,800.00. 

Accordingly it is hereby ORDERED: 

1. The Motion is GRANTED. 

2. Debtor may redeem the subject property by paying Creditor on or before the thirtieth 

(30th) day following the entry of this Order the redemption amount. 

3. Reasonable attorney fees of $700.00 and financing are approved under the terms and 

conditions set forth in the Motion. 

4. Upon timely receipt of such payment, Creditor is ordered to cancel its lien of record and 

surrender the certificate of title in accordance with Debtor’s instructions. 

5. In the event of Creditor’s failure to cancel its lien within three (3) days after payment of 

the aforesaid lump sum pursuant to entry of this Order, then this Order shall serve as an 

authorization for Creditor’s lien to be canceled, and it is Ordered that the applicable 

County Clerk’s Office shall cancel the same of record. 

6. In the event of Debtor’s failure to deliver the redemption amount to Creditor within such 

time frame, the automatic stay shall immediately terminate. 

### 

Submitted by: 

Eric Klein, Esq. 

Florida Bar No.: 0035985 

Klein Law Group, P.A. 

4800 N. Federal Highway, Suite 307-B 

Boca Raton, FL 33431 

Tel. (561) 353-2800 

Fax (561) 210-8549

Attorney Klein is directed to mail a conformed copy of this Order to all interested parties 

immediately upon receipt of this Order and shall file a certification of service with the 

Clerk of the Court.

Case 20-14947-MAM Doc 13 Filed 05/21/20 Page 8 of 8