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LBR 4003-2 provides the procedure for a party to file a motion to avoid a lien when the judgment lien is on real property. Debtors are trying to avoid consensual liens, not judicial liens.By filing a motion to avoid a judicial lien, you just might permanently delete the creditor's legal interest in that property. Pursuant to 11 U.S.C. § 522(f)(1)(A), debtor moves to avoid a judicial lien on real property referenced below and alleges as follows:. PLEASE TAKE NOTICE that the debtor will move this court for an Order pursuant to 11 U.S.C. 522(f) avoiding judicial lien(s) of:. Pursuant to 11 U.S.C. § 522(f) and LBR 9013-1(o), Debtor(s) moved to avoid a judicial lien on real property claimed to be exempt. § 522(h) , subject to 11 U.S.C. § 522(c)(1) . The IRS stipulated to that relief. , 11 U.S.C. § 522(d) (listing of property exempt under federal bankruptcy. The matter before the court is the chapter 13 debtors' motion to avoid a judicial lien pursuant to 11 U.S.C. § 522(f)(1).