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IN THE UNITED STATES BANKRUPTCY COURT FOR THE

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IN THE UNITED STATES BANKRUPTCY COURT FOR THE Powered By Docstoc
					              IN THE UNITED STATES BANKRUPTCY COURT FOR THE
                      WESTERN DISTRICT OF OKLAHOMA

In re: Lillian Gayle Lovejoy                   No. 03-10246-WV
       Randy Charles Lovejoy                   Chapter 7 Pro Se


                         Debtors’ objection and response to creditor
                  First American Bank’s motion to relieve the automatic stay

                                       Brief in support

          1. Debtors under Chapter 7 Bankruptcy are entitled to keep the property contested
by First American Bank by confirming the property.
          2. Debtors, Lillian Gayle Lovejoy and Randy Charles Lovejoy, filed Chjapter 7
bankruptcy in order to have an opportunity to reorganize their total indebtedness to the
Bank and other creditors.
          3. First American Bank has adequate protection. First American Bank has entered
nothing on the record to allege inadequate protection or prejudice to First American’s
rights.
          4. Debtors abandonment of claim to this personal property would result in
extreme hardship and result in prejudice to the rights of Lillian Gayle Lovejoy and Randy
Charles Lovejoy as well as tend to deprive the Lovejoys of their right to work.
          5. Randy Charles Lovejoy has become gainfully employed since the inception of
this bankruptcy and Lillian Gayle Lovejoy has viable prospects for employment within
three weeks.
          6. It is not now, nor has it even been Lillian Gayle Lovejoy and Randy Charles
Lovejoy’s intention to avoid paying any obligation which they lawfully owe.


                                         Conclusion

          The cause of justice will be served by preserving the automatic stay to enable the

bankruptcy to work equitably. Enforcing the bankruptcy stay will not prejudice the

rights of First American. Enforcing the bankruptcy stay will empower Lillian Gayle
Lovejoy and Randy Charles Lovejoy to provide First American Bank with a more just

and expeditious result in the consolidation of First American’s claim.



Prepared and submitted by :__________________________________________

                              Lillian Gayle Lovejoy        Randy Charles Lovejoy

                                  Certificate of mailing

I, Lillian Gayle Lovejoy, certify that February ____, 2003, I mailed a true and correct

copy of the above and foregoing debtors’ objection and response to:



Doug Jackson
_____________________
_____________________


and


Bankruptcy trustee:
______________________
______________________
______________________

				
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