NY Notary Public All-Purpose Acknowledgement Certificate
Motion to Avoid Judicial Lien
THE DEBTOR, by and through counsel Martinez, Law Firm, LLC, moves this court to avoid judicial lien by stating as follows:
1. Debtor commenced this case on October 19, 2011 by filing a voluntary petition for relief under Chapter 7 of Title 11 of the United States Code.
2. The debtor owns real property occupied as his home located at 5943 S. Tempe Way, Aurora, CO 80015, Arapahoe County Colorado. The debtor believes that the value of the homestead is $224,000 as stated in his schedules.
3. Pursuant to 28 USC 1334, this court has jurisdiction over this motion filed under 11 USC 522(f) to avoid and cancel three judicial liens, to wit:
Answer to Mechanics Lien with Affirmative Defenses
Answer that was filed in a multi million dollar lawsuit where the claims where breach of contract and Equitable relief and Lien Foreclosure
A Mechanics Lien Waiver
A sample mechanics lien waiver. Used by property owner for releasing their property from any possible lien
Complaint Filed in Colorado Federal District Court for Defamation, Slander of Title Excessive Lien
A lawsuit complaint filed for defamtion and slander of title and excessive lien
Colorado Lien Notice Disburser
Colorado Mechanic lien notice disburser
Defendant Rule 56 Motion For Summary Judgment (with Attached Brief)
Motion for Summary Judgement in Breach of Contract and Mechanics Lien case. Lawsuit filed by Contractor for payment for service performed and lien case.
Brief in Support of Defendant Motion to Dismiss & Motion for More Definite Statement
Motion to dismiss in a lien case and breach of contract case that was filed by contractor to get paid for alleged work performed.
Findings of Fact & Conclusion of Law in a Contract Dispute & Excessive Mechanics Lien
A 14 page finding of facts and conclusion of law. Contractor sued owner for money owed to them for work performed, Owner counter sued for breach of contract and excessive in lien in Colorado.
Brief on Motion for Summary Judgment on Breach of Contract/excessive lien
Great brief on a breach of construction contract claim and lien, where my client was claiming the lien filed was excessive