In the United States Bankruptcy Court For

IN THE UNITED STATES BANKRUPTCY COURT FOR

THE EASTERN DISTRICT OF TENNESSEE

In re:
______
Debtor(s) / )
)
)
)
) / No. ______
Chapter ____

TRUSTEE’S MOTION TO EXTEND AUTOMATIC STAY

Pursuant to paragraph (2) of 11 U.S.C. § 362(h)(2) the trustee requests an order (i) extending the automatic stay, (ii) that the collateral described below remain property of the estate, (iii) providing appropriate adequate protection of the interest in such property, if any, held by the creditor identified below, and (iv) directing the debtor(s) to deliver any such collateral in the possession of the debtor(s) to the trustee. The trustee makes the following representations in support of this request:

1. The debtor(s) is an individual whose schedule of liabilities includes a debt secured by personal property of the estate, namely: ______.

2. The security interest in such personal property is held or asserted by ______.

3. The trustee believes that the debtor(s) may fail  to file a statement of intention with respect to the retention or surrender of such property in accordance with 11 U.S.C. § 521(a)-(2)(A) within 30 days after the date of the filing of the petition OR  to perform the stated intention with respect to such property in accordance with 11 U.S.C. § 521(a)(2)(B) within 30 days after the first date set for the meeting of creditors.

4. This motion is being filed before the applicable deadline specified in paragraph 2.

5. The personal property described above is of consequential value or benefit to the estate.

6. The interest of the creditor identified above in such property is receiving or may be accorded appropriate adequate protection by ______

______.

7. [any additional pertinent allegations]

______

[insert attorney’s name, office address,

telephone number, and bar number]

CERTIFICATE OF SERVICE

I certify that the foregoing paper will be served electronically on the entities specified in the Notice of Electronic Filing to be issued by the electronic case filing system. I further certify that the foregoing paper was served by mail on the following, at the following addresses, on this date [or] on ______, 20___:

[list of names and addresses of entities served by mail]

This the _____ day of ______, 20___.

______

[insert attorney’s name, office address,

telephone number, and bar number]