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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. Motion to Avoid Liens and Reclassify Claim from Secured to Completely Unsecured.If the judgment creditor does not file a Notice of Satisfaction, you can ask the court to issue an order. Order On Motion To Avoid Junior Lien On Principal Residence {F 40032.4. Before filing an objection, it is important to assess whether a lien creditor has a basis to object to a debtor's claimed homestead exemption. He files a motion to avoid the judgment lien as impairing his exempt interest in his residence. Can the debtor avoid the judicial lien? A subcontractor or material supplier need not serve a notice of furnishing to preserve lien rights for the period before the notice of commencement is recorded. (5) Service of Objection or Motion; Notice of Hearing. If the judgment creditor does not file a Notice of Satisfaction, you can ask the court to issue an order.