B-4003-3. STRIPPING MORTGAGES IN CHAPTER 13 CASES

Any Debtor seeking to strip a mortgage in a Chapter 13 case shall file a separate adversary proceeding as to each lien holder. In addition to any other required allegations, the complaint shall identify:

(a)     the mortgage to be avoided and its approximate amount;

(b)     the other mortgages and liens on the property which the Debtor asserts have higher priority than the mortgage to be avoided, and the amount – listed separately – of those mortgages and liens;

(c)     the value of the property; and

(d)     the common address and legal description of the property.

A proposed judgment tendered by the Debtor shall include both the common address and the legal description of the property.