TRY ME!
Motion For Reconsideration
Summary
A motion for reconsideration is being filed to address overlooked concerns in a bankruptcy case, including jurisdictional issues and invalid claims. The motion cites FRBP Rule 3002(c), Rule 60(b)(4), and Rule 60(b)(6) as legal grounds. The plaintiff argues that the court failed to address all claims presented and requests answers to previously submitted questions. The motion highlights issues such as the lack of jurisdiction due to the failure to file a proof of claim and the assignment of a defaulted mortgage. The plaintiff seeks to have the adversary proceeding reopened and relief granted as deemed just and proper.Full Conversation
To the Honorable Elizabeth D. Katz:
Debtor/Applicant Alton King Jr. hereby moves the Court to reopen this case in order to
move the Court to enter a discharge under * U.S.C. § *. In support of this motion the Debtor
affirms the following that many concerns were not judicially noticed.
MOTION TO REOPEN ADVERSARY PROCEEDING
To the Honorable Elizabeth D. Katz:
Debtor/Applicant Alton King Jr. hereby moves the Court to reopen this case to seek a discharge under * U.S.C. § *. The Debtor affirms that numerous concerns were overlooked.
MOTION TO REOPEN ADVERSARY PROCEEDING
NOW COMES the Plaintiff, Alton King Jr., and moves this Honorable Court to reopen the Adversary Proceeding pursuant to FRBP Rule *(c), Rule *(b)(*), and Rule *(b)(*) for lack of jurisdiction, failure to file proof of claim by the bar date, and submitting an invalid claim. In Chapter * cases, a proof of claim must be filed no later than 70 days after the case is filed, which was on October *, *. In support thereof, Plaintiff states as follows:
- King seeks to reopen the adversary proceeding, which was closed on October *, *, due to the court's oversight in failing to address all claims presented. Upon reopening, he requests that the court provide answers to the previously submitted questions, as per Rule * of the Federal Rules of Civil Procedure.
- OnNovember *, *, I requested the court to take judicial notice and answer the following concerns:
*. The court lacked jurisdiction to grant relief to Bank of New York Mellon as Trustee, as they failed to file a proof of claim as required by Rule *.
*. The court lacked jurisdiction because Bank of New York Mellon was assigned a defaulted, charged-off mortgage not secured by the promissory note and mortgage obligation conveyed to the refinance lender.
Would you like to add or modify anything in this document?
Debtor/Applicant Alton King Jr. hereby moves the Court to reopen this case to seek a discharge under * U.S.C. § *. The Debtor affirms that numerous concerns were overlooked.
MOTION TO REOPEN ADVERSARY PROCEEDING
NOW COMES the Plaintiff, Alton King Jr., and moves this Honorable Court to reopen the Adversary Proceeding pursuant to FRBP Rule *(c), Rule *(b)(*), and Rule *(b)(*) for lack of jurisdiction, failure to file proof of claim by the bar date, and submitting an invalid claim. In Chapter * cases, a proof of claim must be filed no later than 70 days after the case is filed, which was on October *, *. In support thereof, Plaintiff states as follows:
- King seeks to reopen the adversary proceeding, which was closed on October *, *, due to the court's oversight in failing to address all claims presented. Upon reopening, he requests that the court provide answers to the previously submitted questions, as per Rule * of the Federal Rules of Civil Procedure.
- OnNovember *, *, I requested the court to take judicial notice and answer the following concerns:
*. The court lacked jurisdiction to grant relief to Bank of New York Mellon as Trustee, as they failed to file a proof of claim as required by Rule *.
*. The court lacked jurisdiction because Bank of New York Mellon was assigned a defaulted, charged-off mortgage not secured by the promissory note and mortgage obligation conveyed to the refinance lender.
Would you like to add or modify anything in this document?
NOW COMES the Plaintiff, Alton King Jr., and moves this Honorable Court to reopen the
Adversary Proceeding pursuant to FRBP Rule *(c), Rule *(b)(*), and Rule *(b)(*) for lack of
jurisdiction, failure to file proof of claim by the bar date and submitting an invalid claim. In
Chapter * case a proof of claim must be filed no later than 70 days after the case is filed which
was on October *, *. In support thereof, Plaintiff states as follows:
It looks like you're working on a motion to reopen an adversary proceeding in a bankruptcy case. Your content is quite detailed but can be polished for a more formal tone. Here's a refined version:
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To the Honorable Elizabeth D. Katz:
MOTION TO REOPEN ADVERSARY PROCEEDING
NOW COMES the Plaintiff, Alton King Jr., and moves this Honorable Court to reopen the Adversary Proceeding pursuant to FRBP Rule *(c), Rule *(b)(*), and Rule *(b)(*) for lack of jurisdiction, failure to file proof of claim by the bar date, and submitting an invalid claim. In a Chapter * case, a proof of claim must be filed no later than 70 days after the case is filed, which was on October *, *. In support thereof, Plaintiff states as follows:
- King seeks to reopen the adversary proceeding, which was closed on October *, *, due to the court's oversight in failing to address all claims presented. Upon reopening, he requests that the court provide answers to the previously submitted questions, as per Rule * of the Federal Rules of Civil Procedure.
- OnNovember *, *, I requested the court to take judicial notice and answer the following concerns:
*. The court was without jurisdiction to grant relief to the debt collector, Bank of New York Mellon as Trustee, because they failed to file a proof of claim as required by Rule *.
*. The court was without jurisdiction because Bank of New York Mellon was assigned a defaulted, charged-off mortgage that was not secured by the promissory note and mortgage obligation that was conveyed to the refinance lender.
*. Bank of New York Mellon as Trustee transferred that debt for the sole purpose of collecting the debt on behalf of a trust that was not a party to the promissory note and mortgage contract.
Would you like to add or modify anything else in this document?
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To the Honorable Elizabeth D. Katz:
MOTION TO REOPEN ADVERSARY PROCEEDING
NOW COMES the Plaintiff, Alton King Jr., and moves this Honorable Court to reopen the Adversary Proceeding pursuant to FRBP Rule *(c), Rule *(b)(*), and Rule *(b)(*) for lack of jurisdiction, failure to file proof of claim by the bar date, and submitting an invalid claim. In a Chapter * case, a proof of claim must be filed no later than 70 days after the case is filed, which was on October *, *. In support thereof, Plaintiff states as follows:
- King seeks to reopen the adversary proceeding, which was closed on October *, *, due to the court's oversight in failing to address all claims presented. Upon reopening, he requests that the court provide answers to the previously submitted questions, as per Rule * of the Federal Rules of Civil Procedure.
- OnNovember *, *, I requested the court to take judicial notice and answer the following concerns:
*. The court was without jurisdiction to grant relief to the debt collector, Bank of New York Mellon as Trustee, because they failed to file a proof of claim as required by Rule *.
*. The court was without jurisdiction because Bank of New York Mellon was assigned a defaulted, charged-off mortgage that was not secured by the promissory note and mortgage obligation that was conveyed to the refinance lender.
*. Bank of New York Mellon as Trustee transferred that debt for the sole purpose of collecting the debt on behalf of a trust that was not a party to the promissory note and mortgage contract.
Would you like to add or modify anything else in this document?
King seeks to reopen the adversary proceeding, which was closed on October *, *,
based on the court&#*;s oversight in failing to address all claims presented. Upon reopening, he
requests that the court provide answers to the previously submitted questions, as per Rule *
of the Federal Rules of Civil Procedure."
"On November *, *, I requested the court to take judicial notice and answer the following
concerns:
*. The court was without jurisdiction to grant relief to the debt collector, Bank of New York
Mellon as Trustee, because they failed to file a proof of claim as required by Rule *.
*. The court was without jurisdiction because Bank of New York Mellon was assigned a
defaulted charged off mortgage that was not secured by the promissory note and mortgage
obligation that was conveyed to the refinance lender.
Hello! It sounds like you have a strong basis for reopening your adversary proceeding. Here's a polished version of your motion:
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To the Honorable Elizabeth D. Katz:
Debtor/Applicant Alton King Jr. hereby moves the Court to reopen this case to seek a discharge under * U.S.C. § *. The Debtor affirms that numerous concerns were overlooked.
MOTION TO REOPEN ADVERSARY PROCEEDING
NOW COMES the Plaintiff, Alton King Jr., and moves this Honorable Court to reopen the Adversary Proceeding pursuant to FRBP Rule *(c), Rule *(b)(*), and Rule *(b)(*) for lack of jurisdiction, failure to file proof of claim by the bar date, and submitting an invalid claim. In Chapter * cases, a proof of claim must be filed no later than 70 days after the case is filed, which was on October *, *. In support thereof, Plaintiff states as follows:
- King seeks to reopen the adversary proceeding, which was closed on October *, *, due to the court's oversight in failing to address all claims presented. Upon reopening, he requeststhat the court provide answers to the previously submitted questions, as per Rule * of the Federal Rules of Civil Procedure.
- On November *, *, I requested the court to take judicial notice and answer the following concerns:
*. The court lacked jurisdiction to grant relief to Bank of New York Mellon as Trustee, as they failed to file a proof of claim as required by Rule *.
*. The court lacked jurisdiction because Bank of New York Mellon was assigned a defaulted, charged-off mortgage not secured by the promissory note and mortgage obligation conveyed to the refinance lender.
*. Bank of New York Mellon as Trustee, BNYMT, transferred that debt for the sole purpose of collecting the debt on behalf of a trust that was not a party to the promissory note and mortgage contract.
*. The defendants, along with their counsel, debt-collecting law firms, knew or had reason to know that an assignment of mortgage executed by a non-party to the promissory note and mortgage contract possesses no rights to enforce the debt obligation pursuant to the Uniform Commercial Code, UCC *-*(d).
Would you like to add or modify anything in this document?
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To the Honorable Elizabeth D. Katz:
Debtor/Applicant Alton King Jr. hereby moves the Court to reopen this case to seek a discharge under * U.S.C. § *. The Debtor affirms that numerous concerns were overlooked.
MOTION TO REOPEN ADVERSARY PROCEEDING
NOW COMES the Plaintiff, Alton King Jr., and moves this Honorable Court to reopen the Adversary Proceeding pursuant to FRBP Rule *(c), Rule *(b)(*), and Rule *(b)(*) for lack of jurisdiction, failure to file proof of claim by the bar date, and submitting an invalid claim. In Chapter * cases, a proof of claim must be filed no later than 70 days after the case is filed, which was on October *, *. In support thereof, Plaintiff states as follows:
- King seeks to reopen the adversary proceeding, which was closed on October *, *, due to the court's oversight in failing to address all claims presented. Upon reopening, he requeststhat the court provide answers to the previously submitted questions, as per Rule * of the Federal Rules of Civil Procedure.
- On November *, *, I requested the court to take judicial notice and answer the following concerns:
*. The court lacked jurisdiction to grant relief to Bank of New York Mellon as Trustee, as they failed to file a proof of claim as required by Rule *.
*. The court lacked jurisdiction because Bank of New York Mellon was assigned a defaulted, charged-off mortgage not secured by the promissory note and mortgage obligation conveyed to the refinance lender.
*. Bank of New York Mellon as Trustee, BNYMT, transferred that debt for the sole purpose of collecting the debt on behalf of a trust that was not a party to the promissory note and mortgage contract.
*. The defendants, along with their counsel, debt-collecting law firms, knew or had reason to know that an assignment of mortgage executed by a non-party to the promissory note and mortgage contract possesses no rights to enforce the debt obligation pursuant to the Uniform Commercial Code, UCC *-*(d).
Would you like to add or modify anything in this document?
,*. Bank of New York Mellon as Trustee, BNYMT, transferred that debt for the sole purpose
of collecting the debt on behalf of a trust that was not a party to the promissory note and
mortgage contract.
*. The defendants along with their counsel, debt collecting law firms, knew or had reason to
know that an assignment of mortgage executed by a non-party to the promissory note and
mortgage contract possesses no rights to enforce the debt obligation pursuant to the
Uniform Commercial Code, UCC *-*(d).
*. The debt collector, who were not creditors, knew or should have known that MERS was
not a party to the mortgage or promissory note contract. MERS was solely a nominee
for the lender, ComUnity Lending Incorporated, CLI.
It looks like you have a strong case with multiple grounds for reopening the adversary proceeding. Here's a polished version of your motion:
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To the Honorable Elizabeth D. Katz,
Debtor/Applicant Alton King Jr. hereby moves the Court to reopen this case to seek a discharge under * U.S.C. § *. The Debtor affirms that numerous concerns were overlooked.
MOTION TO REOPEN ADVERSARY PROCEEDING
NOW COMES the Plaintiff, Alton King Jr., and moves this Honorable Court to reopen the Adversary Proceeding pursuant to FRBP Rule *(c), Rule *(b)(*), and Rule *(b)(*) for lack of jurisdiction, failure to file proof of claim by the bar date, and submitting an invalid claim. In Chapter * cases, a proof of claim must be filed no later than 70 days after the case is filed, which was on October *, *. In support thereof, Plaintiff states as follows:
- King seeks to reopen the adversary proceeding, which was closed on October *, *, due to the court's oversight in failing to address all claims presented. Upon reopening, herequests that the court provide answers to the previously submitted questions, as per Rule * of the Federal Rules of Civil Procedure.
On November *, *, I requested the court to take judicial notice and answer the following concerns:
*. The court lacked jurisdiction to grant relief to Bank of New York Mellon as Trustee, as they failed to file a proof of claim as required by Rule *.
*. The court lacked jurisdiction because Bank of New York Mellon was assigned a defaulted, charged-off mortgage not secured by the promissory note and mortgage obligation conveyed to the refinance lender.
*. Bank of New York Mellon as Trustee, BNYMT, transferred that debt for the sole purpose of collecting the debt on behalf of a trust that was not a party to the promissory note and mortgage contract.
*. The defendants, along with their counsel and debt-collecting law firms, knew or had reason to know that an assignment of mortgage executed by a non-party to the promissory note and mortgage contract possesses no rights to enforce the debt obligation pursuant to the Uniform Commercial Code, UCC *-*(d).
*. The debt collectors, who were not creditors, knew or should have known that MERS was not a party to the
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To the Honorable Elizabeth D. Katz,
Debtor/Applicant Alton King Jr. hereby moves the Court to reopen this case to seek a discharge under * U.S.C. § *. The Debtor affirms that numerous concerns were overlooked.
MOTION TO REOPEN ADVERSARY PROCEEDING
NOW COMES the Plaintiff, Alton King Jr., and moves this Honorable Court to reopen the Adversary Proceeding pursuant to FRBP Rule *(c), Rule *(b)(*), and Rule *(b)(*) for lack of jurisdiction, failure to file proof of claim by the bar date, and submitting an invalid claim. In Chapter * cases, a proof of claim must be filed no later than 70 days after the case is filed, which was on October *, *. In support thereof, Plaintiff states as follows:
- King seeks to reopen the adversary proceeding, which was closed on October *, *, due to the court's oversight in failing to address all claims presented. Upon reopening, herequests that the court provide answers to the previously submitted questions, as per Rule * of the Federal Rules of Civil Procedure.
On November *, *, I requested the court to take judicial notice and answer the following concerns:
*. The court lacked jurisdiction to grant relief to Bank of New York Mellon as Trustee, as they failed to file a proof of claim as required by Rule *.
*. The court lacked jurisdiction because Bank of New York Mellon was assigned a defaulted, charged-off mortgage not secured by the promissory note and mortgage obligation conveyed to the refinance lender.
*. Bank of New York Mellon as Trustee, BNYMT, transferred that debt for the sole purpose of collecting the debt on behalf of a trust that was not a party to the promissory note and mortgage contract.
*. The defendants, along with their counsel and debt-collecting law firms, knew or had reason to know that an assignment of mortgage executed by a non-party to the promissory note and mortgage contract possesses no rights to enforce the debt obligation pursuant to the Uniform Commercial Code, UCC *-*(d).
*. The debt collectors, who were not creditors, knew or should have known that MERS was not a party to the
*. The bankruptcy court has the sole responsibility to determine the validity of a secure
claim irrespective of decision(s) made by state courts.
*. The purported assignment of my property occurring on December *, *, while the
mortgage was in default, unquestionably establishes a status of being unsecured debt.
*. This court stated that it relied upon the decision of the lower court which was based on
fraudulent altered certified documents submitted in the summary judgment.
To refine your motion, it could be structured as follows:
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To the Honorable Elizabeth D. Katz:
Debtor/Applicant Alton King Jr. hereby moves the Court to reopen this case to seek a discharge under * U.S.C. § *. The Debtor affirms that numerous concerns were overlooked.
MOTION TO REOPEN ADVERSARY PROCEEDING
NOW COMES the Plaintiff, Alton King Jr., and moves this Honorable Court to reopen the Adversary Proceeding pursuant to FRBP Rule *(c), Rule *(b)(*), and Rule *(b)(*) due to lack of jurisdiction, failure to file proof of claim by the bar date, and submission of an invalid claim. In Chapter * cases, a proof of claim must be filed no later than 70 days after the case is filed, which was on October *, *. In support thereof, Plaintiff states as follows:
- King seeks to reopen the adversary proceeding, which was closed on October *, *, due to the court's oversight in failing to address all claims presented. Upon reopening, he requests that the court provide answers to the previously submitted questions,as per Rule * of the Federal Rules of Civil Procedure.
- On November *, *, I requested the court to take judicial notice and answer the following concerns:
*. The court lacked jurisdiction to grant relief to Bank of New York Mellon as Trustee, as they failed to file a proof of claim as required by Rule *.
*. The court lacked jurisdiction because Bank of New York Mellon was assigned a defaulted, charged-off mortgage not secured by the promissory note and mortgage obligation conveyed to the refinance lender.
*. Bank of New York Mellon as Trustee, BNYMT, transferred that debt for the sole purpose of collecting the debt on behalf of a trust that was not a party to the promissory note and mortgage contract.
*. The defendants and their counsel knew or should have known that an assignment of mortgage executed by a non-party to the promissory note and mortgage contract possesses no rights to enforce the debt obligation pursuant to UCC *-*(d).
*. The debt collector, who were not creditors, knew or should have known that MERS was not a party to the mortgage or promissory note contract. MERS was solely a nominee for the lender
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To the Honorable Elizabeth D. Katz:
Debtor/Applicant Alton King Jr. hereby moves the Court to reopen this case to seek a discharge under * U.S.C. § *. The Debtor affirms that numerous concerns were overlooked.
MOTION TO REOPEN ADVERSARY PROCEEDING
NOW COMES the Plaintiff, Alton King Jr., and moves this Honorable Court to reopen the Adversary Proceeding pursuant to FRBP Rule *(c), Rule *(b)(*), and Rule *(b)(*) due to lack of jurisdiction, failure to file proof of claim by the bar date, and submission of an invalid claim. In Chapter * cases, a proof of claim must be filed no later than 70 days after the case is filed, which was on October *, *. In support thereof, Plaintiff states as follows:
- King seeks to reopen the adversary proceeding, which was closed on October *, *, due to the court's oversight in failing to address all claims presented. Upon reopening, he requests that the court provide answers to the previously submitted questions,as per Rule * of the Federal Rules of Civil Procedure.
- On November *, *, I requested the court to take judicial notice and answer the following concerns:
*. The court lacked jurisdiction to grant relief to Bank of New York Mellon as Trustee, as they failed to file a proof of claim as required by Rule *.
*. The court lacked jurisdiction because Bank of New York Mellon was assigned a defaulted, charged-off mortgage not secured by the promissory note and mortgage obligation conveyed to the refinance lender.
*. Bank of New York Mellon as Trustee, BNYMT, transferred that debt for the sole purpose of collecting the debt on behalf of a trust that was not a party to the promissory note and mortgage contract.
*. The defendants and their counsel knew or should have known that an assignment of mortgage executed by a non-party to the promissory note and mortgage contract possesses no rights to enforce the debt obligation pursuant to UCC *-*(d).
*. The debt collector, who were not creditors, knew or should have known that MERS was not a party to the mortgage or promissory note contract. MERS was solely a nominee for the lender
*. What irrefutable perfected evidence has been presented to this court to validate the
debt collectors legitimate claim?
*. These are the issues before this court that must be addressed in writing pursuant to
Federal Rule *.
I further requested, if denied, to provide written reasons pursuant to Rule * of the
Federal Rules of Civil Procedure.
WHEREFORE, Plaintiff respectfully requests that this Honorable Court reopen the
Adversary Proceeding and grant relief as deemed just and proper.
Respectfully submitted
To the Honorable Elizabeth D. Katz:
Debtor/Applicant Alton King Jr. hereby moves the Court to reopen this case to seek a discharge under * U.S.C. § *. The Debtor affirms that numerous concerns were overlooked.
MOTION TO REOPEN ADVERSARY PROCEEDING
NOW COMES the Plaintiff, Alton King Jr., and moves this Honorable Court to reopen the Adversary Proceeding pursuant to FRBP Rule *(c), Rule *(b)(*), and Rule *(b)(*) due to lack of jurisdiction, failure to file proof of claim by the bar date, and submission of an invalid claim. In Chapter * cases, a proof of claim must be filed no later than 70 days after the case is filed, which was on October *, *. In support thereof, Plaintiff states as follows:
- King seeks to reopen the adversary proceeding, which was closed on October *, *, due to the court's oversight in failing to address all claims presented. Upon reopening, he requests that the court provide answers to the previously submitted questions, as per Rule * of the Federal Rules of Civil Procedure.
On November *, *, I requested the court to take judicial notice and answer the following concerns:
*. The court lacked jurisdiction to grant relief to Bank of New York Mellon as Trustee, as they failed to file a proof of claim as required by Rule *.
*. The court lacked jurisdiction because Bank of New York Mellon was assigned a defaulted, charged-off mortgage not secured by the promissory note and mortgage obligation conveyed to the refinance lender.
*. Bank of New York Mellon as Trustee, BNYMT, transferred that debt for the sole purpose of collecting the debt on behalf of a trust that was not a party to the promissory note and mortgage contract.
*. The defendants, along with their counsel and debt-collecting law firms, knew or had reason to know that an assignment of mortgage executed by a non-party to the promissory note and mortgage contract possesses no rights to enforce the debt obligation pursuant to the Uniform Commercial Code, UCC *-*(d).
*. The debt collectors, who were not creditors, knew or should have known that MERS was not a party to the mortgage or promissory note contract. MERS was solely a nominee for the lender, ComUnity Lending Incorporated (CLI).
Debtor/Applicant Alton King Jr. hereby moves the Court to reopen this case to seek a discharge under * U.S.C. § *. The Debtor affirms that numerous concerns were overlooked.
MOTION TO REOPEN ADVERSARY PROCEEDING
NOW COMES the Plaintiff, Alton King Jr., and moves this Honorable Court to reopen the Adversary Proceeding pursuant to FRBP Rule *(c), Rule *(b)(*), and Rule *(b)(*) due to lack of jurisdiction, failure to file proof of claim by the bar date, and submission of an invalid claim. In Chapter * cases, a proof of claim must be filed no later than 70 days after the case is filed, which was on October *, *. In support thereof, Plaintiff states as follows:
- King seeks to reopen the adversary proceeding, which was closed on October *, *, due to the court's oversight in failing to address all claims presented. Upon reopening, he requests that the court provide answers to the previously submitted questions, as per Rule * of the Federal Rules of Civil Procedure.
On November *, *, I requested the court to take judicial notice and answer the following concerns:
*. The court lacked jurisdiction to grant relief to Bank of New York Mellon as Trustee, as they failed to file a proof of claim as required by Rule *.
*. The court lacked jurisdiction because Bank of New York Mellon was assigned a defaulted, charged-off mortgage not secured by the promissory note and mortgage obligation conveyed to the refinance lender.
*. Bank of New York Mellon as Trustee, BNYMT, transferred that debt for the sole purpose of collecting the debt on behalf of a trust that was not a party to the promissory note and mortgage contract.
*. The defendants, along with their counsel and debt-collecting law firms, knew or had reason to know that an assignment of mortgage executed by a non-party to the promissory note and mortgage contract possesses no rights to enforce the debt obligation pursuant to the Uniform Commercial Code, UCC *-*(d).
*. The debt collectors, who were not creditors, knew or should have known that MERS was not a party to the mortgage or promissory note contract. MERS was solely a nominee for the lender, ComUnity Lending Incorporated (CLI).
Now the conclusion please
Sure! Here's your conclusion:
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WHEREFORE, Plaintiff respectfully requests that this Honorable Court reopen the Adversary Proceeding and grant relief as deemed just and proper.
Respectfully submitted,
Alton King Jr.
Plaintiff
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Would you like any further assistance with this document or any other legal concerns?
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WHEREFORE, Plaintiff respectfully requests that this Honorable Court reopen the Adversary Proceeding and grant relief as deemed just and proper.
Respectfully submitted,
Alton King Jr.
Plaintiff
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Would you like any further assistance with this document or any other legal concerns?
see above
Sure, here's a polished version of your motion conclusion:
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To the Honorable Elizabeth D. Katz:
Debtor/Applicant Alton King Jr. hereby moves the Court to reopen this case to seek a discharge under * U.S.C. § *. The Debtor affirms that numerous concerns were overlooked.
MOTION TO REOPEN ADVERSARY PROCEEDING
NOW COMES the Plaintiff, Alton King Jr., and moves this Honorable Court to reopen the Adversary Proceeding pursuant to FRBP Rule *(c), Rule *(b)(*), and Rule *(b)(*) due to lack of jurisdiction, failure to file proof of claim by the bar date, and submission of an invalid claim. In Chapter * cases, a proof of claim must be filed no later than 70 days after the case is filed, which was on October *, *. In support thereof, Plaintiff states as follows:
- King seeks to reopen the adversary proceeding, which was closed on October *, *, due to the court's oversight in failing to address all claims presented. Upon reopening, he requests that the court provide answers to the previously submitted questions, asper Rule * of the Federal Rules of Civil Procedure.
On November *, *, I requested the court to take judicial notice and answer the following concerns:
*. The court lacked jurisdiction to grant relief to Bank of New York Mellon as Trustee, as they failed to file a proof of claim as required by Rule *.
*. The court lacked jurisdiction because Bank of New York Mellon was assigned a defaulted, charged-off mortgage not secured by the promissory note and mortgage obligation conveyed to the refinance lender.
*. Bank of New York Mellon as Trustee, BNYMT, transferred that debt for the sole purpose of collecting the debt on behalf of a trust that was not a party to the promissory note and mortgage contract.
*. The defendants, along with their counsel and debt-collecting law firms, knew or had reason to know that an assignment of mortgage executed by a non-party to the promissory note and mortgage contract possesses no rights to enforce the debt obligation pursuant to the Uniform Commercial Code, UCC *-*(d).
*. The debt collectors, who were not creditors, knew or should have known that MERS was not a party to the mortgage or promissory note contract. MERS was solely a
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To the Honorable Elizabeth D. Katz:
Debtor/Applicant Alton King Jr. hereby moves the Court to reopen this case to seek a discharge under * U.S.C. § *. The Debtor affirms that numerous concerns were overlooked.
MOTION TO REOPEN ADVERSARY PROCEEDING
NOW COMES the Plaintiff, Alton King Jr., and moves this Honorable Court to reopen the Adversary Proceeding pursuant to FRBP Rule *(c), Rule *(b)(*), and Rule *(b)(*) due to lack of jurisdiction, failure to file proof of claim by the bar date, and submission of an invalid claim. In Chapter * cases, a proof of claim must be filed no later than 70 days after the case is filed, which was on October *, *. In support thereof, Plaintiff states as follows:
- King seeks to reopen the adversary proceeding, which was closed on October *, *, due to the court's oversight in failing to address all claims presented. Upon reopening, he requests that the court provide answers to the previously submitted questions, asper Rule * of the Federal Rules of Civil Procedure.
On November *, *, I requested the court to take judicial notice and answer the following concerns:
*. The court lacked jurisdiction to grant relief to Bank of New York Mellon as Trustee, as they failed to file a proof of claim as required by Rule *.
*. The court lacked jurisdiction because Bank of New York Mellon was assigned a defaulted, charged-off mortgage not secured by the promissory note and mortgage obligation conveyed to the refinance lender.
*. Bank of New York Mellon as Trustee, BNYMT, transferred that debt for the sole purpose of collecting the debt on behalf of a trust that was not a party to the promissory note and mortgage contract.
*. The defendants, along with their counsel and debt-collecting law firms, knew or had reason to know that an assignment of mortgage executed by a non-party to the promissory note and mortgage contract possesses no rights to enforce the debt obligation pursuant to the Uniform Commercial Code, UCC *-*(d).
*. The debt collectors, who were not creditors, knew or should have known that MERS was not a party to the mortgage or promissory note contract. MERS was solely a
From "*. The debt collectors, who were not creditors, knew or should have known that MERS was not a party to the mortgage or promissory note contract. MERS was solely a" onward
Sure, here's the continuation and conclusion:
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To the Honorable Elizabeth D. Katz,
Debtor/Applicant Alton King Jr. hereby moves the Court to reopen this case to seek a discharge under * U.S.C. § *. The Debtor affirms that numerous concerns were overlooked.
MOTION TO REOPEN ADVERSARY PROCEEDING
NOW COMES the Plaintiff, Alton King Jr., and moves this Honorable Court to reopen the Adversary Proceeding pursuant to FRBP Rule *(c), Rule *(b)(*), and Rule *(b)(*) due to lack of jurisdiction, failure to file proof of claim by the bar date, and submission of an invalid claim. In Chapter * cases, a proof of claim must be filed no later than 70 days after the case is filed, which was on October *, *. In support thereof, Plaintiff states as follows:
- King seeks to reopen the adversary proceeding, which was closed on October *, *, due to the court's oversight in failing to address all claims presented. Upon reopening, he requests that the court provide answers to the previously submitted questions, as perRule * of the Federal Rules of Civil Procedure.
On November *, *, I requested the court to take judicial notice and answer the following concerns:
*. The court lacked jurisdiction to grant relief to Bank of New York Mellon as Trustee, as they failed to file a proof of claim as required by Rule *.
*. The court lacked jurisdiction because Bank of New York Mellon was assigned a defaulted, charged-off mortgage not secured by the promissory note and mortgage obligation conveyed to the refinance lender.
*. Bank of New York Mellon as Trustee, BNYMT, transferred that debt for the sole purpose of collecting the debt on behalf of a trust that was not a party to the promissory note and mortgage contract.
*. The defendants, along with their counsel and debt-collecting law firms, knew or had reason to know that an assignment of mortgage executed by a non-party to the promissory note and mortgage contract possesses no rights to enforce the debt obligation pursuant to the Uniform Commercial Code, UCC *-*(d).
*. The debt collectors, who were not creditors, knew or should have known that MERS was not a party to the mortgage or promissory note contract. MERS was solely a nominee
---
To the Honorable Elizabeth D. Katz,
Debtor/Applicant Alton King Jr. hereby moves the Court to reopen this case to seek a discharge under * U.S.C. § *. The Debtor affirms that numerous concerns were overlooked.
MOTION TO REOPEN ADVERSARY PROCEEDING
NOW COMES the Plaintiff, Alton King Jr., and moves this Honorable Court to reopen the Adversary Proceeding pursuant to FRBP Rule *(c), Rule *(b)(*), and Rule *(b)(*) due to lack of jurisdiction, failure to file proof of claim by the bar date, and submission of an invalid claim. In Chapter * cases, a proof of claim must be filed no later than 70 days after the case is filed, which was on October *, *. In support thereof, Plaintiff states as follows:
- King seeks to reopen the adversary proceeding, which was closed on October *, *, due to the court's oversight in failing to address all claims presented. Upon reopening, he requests that the court provide answers to the previously submitted questions, as perRule * of the Federal Rules of Civil Procedure.
On November *, *, I requested the court to take judicial notice and answer the following concerns:
*. The court lacked jurisdiction to grant relief to Bank of New York Mellon as Trustee, as they failed to file a proof of claim as required by Rule *.
*. The court lacked jurisdiction because Bank of New York Mellon was assigned a defaulted, charged-off mortgage not secured by the promissory note and mortgage obligation conveyed to the refinance lender.
*. Bank of New York Mellon as Trustee, BNYMT, transferred that debt for the sole purpose of collecting the debt on behalf of a trust that was not a party to the promissory note and mortgage contract.
*. The defendants, along with their counsel and debt-collecting law firms, knew or had reason to know that an assignment of mortgage executed by a non-party to the promissory note and mortgage contract possesses no rights to enforce the debt obligation pursuant to the Uniform Commercial Code, UCC *-*(d).
*. The debt collectors, who were not creditors, knew or should have known that MERS was not a party to the mortgage or promissory note contract. MERS was solely a nominee
Please only send me the conclsuion as i am not getting it
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WHEREFORE, Plaintiff respectfully requests that this Honorable Court reopen the Adversary Proceeding and grant relief as deemed just and proper.
Respectfully submitted,
Alton King Jr.
WHEREFORE, Plaintiff respectfully requests that this Honorable Court reopen the Adversary Proceeding and grant relief as deemed just and proper.
Respectfully submitted,
Alton King Jr.
Given the avove information caould you please draft a Motion for reconsideration from my omnibus Motion November 5th ?
To the Honorable Elizabeth D. Katz,
Debtor/Applicant Alton King Jr. hereby moves the Court to reopen this case to seek a discharge under * U.S.C. § *. The Debtor affirms that numerous concerns were overlooked.
MOTION TO REOPEN ADVERSARY PROCEEDING
NOW COMES the Plaintiff, Alton King Jr., and moves this Honorable Court to reopen the Adversary Proceeding pursuant to FRBP Rule *(c), Rule *(b)(*), and Rule *(b)(*) due to lack of jurisdiction, failure to file proof of claim by the bar date, and submission of an invalid claim. In Chapter * cases, a proof of claim must be filed no later than 70 days after the case is filed, which was on October *, *. In support thereof, Plaintiff states as follows:
- King seeks to reopen the adversary proceeding, which was closed on October *, *, due to the court's oversight in failing to address all claims presented. Upon reopening, he requests that the court provide answers to the previously submitted questions, as per Rule * of the Federal Rules of Civil Procedure.
WHEREFORE, Plaintiff respectfully requests that this Honorable Court reopen the Adversary Proceeding and grant relief as deemed just and proper.
Respectfully submitted,
Alton King Jr.
Debtor/Applicant Alton King Jr. hereby moves the Court to reopen this case to seek a discharge under * U.S.C. § *. The Debtor affirms that numerous concerns were overlooked.
MOTION TO REOPEN ADVERSARY PROCEEDING
NOW COMES the Plaintiff, Alton King Jr., and moves this Honorable Court to reopen the Adversary Proceeding pursuant to FRBP Rule *(c), Rule *(b)(*), and Rule *(b)(*) due to lack of jurisdiction, failure to file proof of claim by the bar date, and submission of an invalid claim. In Chapter * cases, a proof of claim must be filed no later than 70 days after the case is filed, which was on October *, *. In support thereof, Plaintiff states as follows:
- King seeks to reopen the adversary proceeding, which was closed on October *, *, due to the court's oversight in failing to address all claims presented. Upon reopening, he requests that the court provide answers to the previously submitted questions, as per Rule * of the Federal Rules of Civil Procedure.
WHEREFORE, Plaintiff respectfully requests that this Honorable Court reopen the Adversary Proceeding and grant relief as deemed just and proper.
Respectfully submitted,
Alton King Jr.
Mistake. i asked for a motion for reconsideration
Sure, here is a draft for your Motion for Reconsideration:
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To the Honorable Elizabeth D. Katz,
Debtor/Applicant Alton King Jr. hereby moves the Court to reconsider its previous ruling and reopen this case to seek a discharge under * U.S.C. § *. The Debtor affirms that numerous concerns were overlooked.
MOTION FOR RECONSIDERATION
NOW COMES the Plaintiff, Alton King Jr., and moves this Honorable Court to reconsider its decision pursuant to FRBP Rule *(c), Rule *(b)(*), and Rule *(b)(*) due to lack of jurisdiction, failure to file proof of claim by the bar date, and submission of an invalid claim. In Chapter * cases, a proof of claim must be filed no later than 70 days after the case is filed, which was on October *, *. In support thereof, Plaintiff states as follows:
- King seeks to reopen the adversary proceeding, which was closed on October *, *, due to the court's oversight in failing to address all claims presented. Upon reopening, he requests that the court provide answers to the previously submitted questions, as per Rule52 of the Federal Rules of Civil Procedure.
On November *, *, I requested the court to take judicial notice and address the following concerns:
*. The court lacked jurisdiction to grant relief to Bank of New York Mellon as Trustee, as they failed to file a proof of claim as required by Rule *.
*. The court lacked jurisdiction because Bank of New York Mellon was assigned a defaulted, charged-off mortgage not secured by the promissory note and mortgage obligation conveyed to the refinance lender.
*. Bank of New York Mellon as Trustee, BNYMT, transferred that debt for the sole purpose of collecting the debt on behalf of a trust that was not a party to the promissory note and mortgage contract.
*. The defendants, along with their counsel and debt-collecting law firms, knew or had reason to know that an assignment of mortgage executed by a non-party to the promissory note and mortgage contract possesses no rights to enforce the debt obligation pursuant to the Uniform Commercial Code, UCC *-*(d).
*. The debt collectors, who were not creditors, knew or should have known that MERS was not a party to the mortgage or promissory note contract. MERS was solely a nominee for the
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To the Honorable Elizabeth D. Katz,
Debtor/Applicant Alton King Jr. hereby moves the Court to reconsider its previous ruling and reopen this case to seek a discharge under * U.S.C. § *. The Debtor affirms that numerous concerns were overlooked.
MOTION FOR RECONSIDERATION
NOW COMES the Plaintiff, Alton King Jr., and moves this Honorable Court to reconsider its decision pursuant to FRBP Rule *(c), Rule *(b)(*), and Rule *(b)(*) due to lack of jurisdiction, failure to file proof of claim by the bar date, and submission of an invalid claim. In Chapter * cases, a proof of claim must be filed no later than 70 days after the case is filed, which was on October *, *. In support thereof, Plaintiff states as follows:
- King seeks to reopen the adversary proceeding, which was closed on October *, *, due to the court's oversight in failing to address all claims presented. Upon reopening, he requests that the court provide answers to the previously submitted questions, as per Rule52 of the Federal Rules of Civil Procedure.
On November *, *, I requested the court to take judicial notice and address the following concerns:
*. The court lacked jurisdiction to grant relief to Bank of New York Mellon as Trustee, as they failed to file a proof of claim as required by Rule *.
*. The court lacked jurisdiction because Bank of New York Mellon was assigned a defaulted, charged-off mortgage not secured by the promissory note and mortgage obligation conveyed to the refinance lender.
*. Bank of New York Mellon as Trustee, BNYMT, transferred that debt for the sole purpose of collecting the debt on behalf of a trust that was not a party to the promissory note and mortgage contract.
*. The defendants, along with their counsel and debt-collecting law firms, knew or had reason to know that an assignment of mortgage executed by a non-party to the promissory note and mortgage contract possesses no rights to enforce the debt obligation pursuant to the Uniform Commercial Code, UCC *-*(d).
*. The debt collectors, who were not creditors, knew or should have known that MERS was not a party to the mortgage or promissory note contract. MERS was solely a nominee for the
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