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The fair market value of the Property is. 5. Senior lien s or mortgage s payable to insert senior lienholder s name s and totaling encumber s the Property. 6. Creditor holds a wholly unsecured claim. WHEREFORE Debtor requests the entry of an order i granting this motion ii determining that the value of the Property is iii determining that Creditor s claim is unsecured and iv voiding the Creditor s junior mortgage or lien upon completion of the Chapter 13 plan and v any other relief the Court...
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