Consider if you will that your client has just filed a Chapter 13 Bankruptcy. They have intelligently chosen to surrender a luxury item - a boat or 4-wheeler or even that extra vehicle they don’t need.
Because the creditor would like to preserve the value of the collateral by obtaining possession quickly, they file a Motion for Relief shortly after the case is filed.
You hardly take notice of the motion because once you glance at the Motion for Relief and realize it is for collateral your client has already surrendered, you no longer . . .
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