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.
The court will not consider motions related to contested discovery unless, prior to the filing of the motion, the parties have conferred, through direct dialogue and discussion either in person or by telephone, and attempted to resolve their differences in good faith. Any discovery motion filed with the court shall include a statement of compliance with this requirement. The statement must contain sufficient facts to allow the court to evaluate the adequacy of the parties’ compliance or noncompliance with the meet and confer requirement. Failure to satisfy the meet and confer requirement and/or failure to include a statement of compliance with the discovery motion may result in denial of the motion.