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The Debtor states that the Respondent's Judgment Lien impairs the Debtor's exemption following the formula set forth in 11 U.S.C. § 522(f)(2):. 522(f) Judicial Lien Avoidance Motion and Proposed Order.Form: PDF icon 522(f) - Judicial Lien Avoidance Motion and Proposed Order.pdf. The Court finds that the avoidance of a judicial lien pursuant to Section 522(f) of the. On December 12, 2006, Debtor's bankruptcy counsel, Michael Sachs, moved to reopen the case in order to avoid a judicial lien pursuant to 11 U.S.C. § 522(f). 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:. § 522(f), a debtor may avoid the attachment of a judicial lien to his interest in property to the extent that the lien impairs the debtor's homestead exemption. The lien impairs an exemption of the debtor(s) and is subject to avoidance under 11 U.S.C. §522(f). 7. 8. 9. (a) A motion to avoid a judicial lien pursuant to 11 U.S.C. § 522(f)(1)(A) shall include a proposed order that conforms to Local Form 4003-2(a). Bankruptcy allows avoidance of liens impairing the debtor's exemptions.