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The chapter 13 plan must indicate that the debtor intends to file a motion to avoid a junior lien on the debtor's residence. The court provides forms.Motion will be deemed unopposed and the Court may enter an order granting the relief sought. What you get: Instant access to fillable Microsoft Word or PDF forms. That the avoidance of the Respondent's junior lien is contingent upon: The Debtor's completion of the chapter 13 plan, or receipt of a chapter 13 discharge. e. This Court declined to permit the lien avoidance in Nobelman solely because § 1322(b)(2), which applies only in Chapter 13, states that a plan cannot "modify. One of the tools available in a Chapter 13 reorganization is lien voidance, or "lien stripping. – If retaining, debtor will: • Reaffirm the debt;. • Redeem the property;. Threshold issue of whether the Bankruptcy Code permits a Chapter 13 debtor to avoid a secured mortgage lien.