Motions to Extend Stay
Motions to Reduce Time Period for Notice
a. The specific time period the movant seeks to shorten, including a citation to the appropriate rule;
b. An averment that reduction of time is not prohibited by Fed. R. Bankr. P. 9006(c)(2); and
c. The reason or cause pursuant to Fed. R. Bankr. P. 9006(c)(1) for seeking the reduction.
Motion for Sale of Property Post-Confirmation in a Chapter 13 Case
a. An identification of the property proposed to be sold, including the legal and common description of real property;
b. A statement indicating whether, under Section IV(B) of the confirmed plan, the property proposed to be sold remained property of the estate or vested in the debtor at confirmation; and
c. A statement indicating whether the movant is seeking to sell the property pursuant to 11 U.S.C. § 363(b) and/or § 363(f), or is simply seeking a “comfort order” approving the sale.
Motion to Incur Debt Post-Confirmation in a Chapter 13 Case
If the Debtor seeks the Court’s authority to incur debt pursuant to Section IV(C) of a confirmed plan:
a. File the motion under Notice with Opportunity to Object [14-day notice period] pursuant to LBR 9013(c)(1); or
b. File the motion and request a hearing on the motion, which will be scheduled in accordance with Fed. R. Bankr. P. 9006(d) [notice of hearing at least 7 days prior to hearing].
 Please review Fed. R. Bankr. P. 9006(d) prior to filing this type of motion.
a. Agreeing that the fact is undisputed;
b. Agreeing that the fact is undisputed for the purposes of summary judgmnent only; or
c. Stating that the fact is disputed as demonstrated by specific citation to material allowed by Fed. R. Civ. P. 56(c).
The response may also include a statement of additional material facts that the respondent contends are disputed and require denial of the motion.