UNITED STATES BANKRUPTCY COURT

MIDDLE DISTRICT OF FLORIDA

ORLANDO DIVISION

In re: Case No.:

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Debtors.
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VERIFIED MOTION FOR VALUATION OF CLAIM

AND ALLOWING BALANCE OF CLAIM AS GENERAL UNSECURED CLAIM

COME NOW the Debtors, and , by and through

their undersigned counsel, pursuant to 11 U.S.C. § 506(a) and Bankruptcy Rule 3012, and move this

Honorable Court for entry of an Order For Valuation of Secured Claim and Allowing the Balance as

an Unsecured Claim as to the Claim of Creditor, and state as follows:

NOTICE OF OPPORTUNITY TO OBJECT AND FOR HEARING:

Pursuant to Local Rule 2002-4, the Court will consider this motion, objection, or
other matter without further notice or hearing unless a party in interest files an objection
within 21 days from the date this paper is entered on the docket. If you object to the relief
requested in this paper, you must file your objection with the Clerk of the Court at 135 W.
Central Blvd., Suite 950, Orlando, FL 32801, and serve a copy on the movant’s attorney,

If you file and serve an objection within the time permitted, the Court will schedule a
hearing and you will be notified. If you do not file an objection within the time permitted,
the Court will consider that you do not oppose the granting of the relief requested in the
paper, will proceed to consider the paper without further notice or hearing, and may grant
the relief requested.

1. The Debtors owe the sum of $5,332.50, which sum is secured by a lien on

property of the Debtors consisting of solar panels (“Merchandise”).

2. The Debtors believe that the Fair Market Value for the merchandise is $1,500.00, and
therefore, the value of the interest of is no more than $1,500.00.
 3. The balance of any claim of is allowable only as a general unsecured claim.

WHEREFORE, the Debtors, by and through their undersigned attorney, respectfully request

this Court to:

a. Value the interest of in the merchandise at $1,500.00;

b. Determine the allowed secured Claim of to be $1,500.00 at 5.25%

interest, with the balance allowed as a general unsecured claim; and

c. Grant such other relief as maybe necessary and proper under the Law.

DECLARATION OF DEBTORS
I declare under penalty of perjury that I have read the foregoing Motion, and that it is true and

correct to the best of my knowledge, information, and belief.

Date: _______________ ______________________________

Date: _______________ ______________________________

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a true and correct copy of the foregoing Motion has been
furnished by Electronic Notice or First Class U.S. Mail, postage pre-paid, on this ______ day of
___________________, 2011, to: ,

/s/ Matthew P. Tabakman

MATTHEW P. TABAKMAN, ESQ.
Florida Bar No.: 0558141
MATTHEW P. TABAKMAN, P.A.
5401 S. Kirkman Rd., Suite 310
Orlando, FL 32819
Tel.: (407) 926-0324
Fax: (407) 926-0325
Email: matt@tabakmanlaw.com