UNITED STATES BANKRUPTCY COURT

SOUTHERN DISTRICT OF FLORIDA

MIAMI DIVISION

www.flsb.uscourts.gov

In re: Case No.: 20-13368-LMI

Cynthia E. Ortiz, Chapter 7

Debtor. /

DEBTOR’S MOTION FOR AUTHORITY TO REDEEM 

PERSONAL PROPERTY AND APPROVAL OF ASSOCIATED 

FINANCING AND ATTORNEY FEES UNDER 11 U.S.C. §722

 The Debtor, Cynthia E. Ortiz, by and through the undersigned counsel, moves the 

Court, pursuant to 11 U.S.C. §722 and Bankruptcy Rule 6008, for a Redemption Order, and in 

support thereof states:

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

family or household use is more particularly described as follows:

2019 Honda Civic Sedan 4D

VIN No.: 19XFC2F6XKE026608

2. The interest of the Debtor 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 Capital One Auto Finance, a division of Capital One, N.A.

(“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 $16,425.00 as per 

agreement between the parties. 

4. Arrangements have been made by the Debtor 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 

Case 20-13368-LMI Doc 33 Filed 06/15/20 Page 1 of 2
disperse additional funds in the amount of $700.00, from their loan with Prizm 

Financial Co. LLC, for representation of the Debtor in securing for the benefit of the 

Debtor an order granting the Debtor 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, Cynthia E. Ortiz, respectfully requests the Court to order the 

said Creditor to accept from the Debtor the lump sum payment of the redemption value and release 

the lien of record and for whatever further relief this Honorable Court deems just and proper. In 

the event the said Creditor objects to this Motion, the Debtor requests the Court to determine the 

value of the property as of the time of the hearing on such objection, and for whatever further relief 

this Honorable Court deems just and proper. 

Respectfully submitted this 15th day of June 2020. 

VAN HORN LAW GROUP, P.A.

330 N. Andrews Ave., Suite 450

Fort Lauderdale, Florida 33301

(954) 765-3166

(954) 756-7103 (facsimile)

Chad@cvhlawgroup.com

By: /s/ Chad T. Van Horn, Esq.

Chad T. Van Horn, Esq.

Florida Bar #64500

Case 20-13368-LMI Doc 33 Filed 06/15/20 Page 2 of 2