Opposition to Continuing Automatic Stay per 11 USCA 362(c)(3)(B)



Ladies and Gentlemen:

Has anyone on this list yet been served with (or otherwise have a
copy of) a creditor's response in opposition to a motion to continue
the automatic stay under 11 USCA 362(c)(3)(B)?

I anticipate such a response to be filed in a case of mine very
soon. I'm trying to anticipate what might be coming. Are creditors
filing brief responses in opposition and relying on the (c)(3)(C)
presumption of bad faith, or are they itemizing the reasons why a
debtor's stay ought not be continued?

This is a case in which the debtor had a case dismissed in October of
this year w/o prejudice against refiling. So the stay is in place
for 30 days, but after that...

If you have such a response, I'd like to see it if you wouldn't mind
sending it along to the group or to me individually.

Thanks in advance,

Richard S. Barid
Attorney at Law
(e-mail address removed)


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