In the United States Bankruptcy Court For

IN THE UNITED STATES BANKRUPTCY COURT FOR

THE EASTERN DISTRICT OF TENNESSEE

In re:
______
Debtor(s) / )
)
)
)
) / No. ______
Chapter ____

MOTION TO IMPOSE STAY

Pursuant to 11 U.S.C. § 362(c)(4)(B), the debtor(s) request(s) an order imposing a stay, and make(s) the following representations in support of this request:

1. Two or more cases of the debtor(s) were pending within the year preceding the commencement of this case but were dismissed. The numbers of the previous cases and the reasons for their dismissal are as follows:

Case No. / Reason for Dismissal

2. The debtor(s) seek(s) the imposition of the stay against all creditors OR  the following creditors: ______.

3. This case was commenced in good faith. Although the case was presumptively filed not in good faith, the debtor(s) can present clear and convincing evidence of the following facts rebutting the presumption: ______

______

______

______

______.

4. [any additional pertinent allegations]

______

[insert attorney’s name, office address,

telephone number, and bar number]

Verification

[optional]

The undersigned declare(s) under penalty of perjury that the facts set forth in the foregoing motion are true and correct.

______

[signature] [date]

______

[signature] [date]

CERTIFICATE OF SERVICE

I certify that the foregoing paper will be served electronically on the entities specified in the Notice of Electronic Filing to be issued by the electronic case filing system. I further certify that the foregoing paper was served by  fax  e-mail  another method effecting immediate receipt (______) on the following, at the following fax numbers, e-mail addresses, or addresses on this date [or] on ______, 20___:

[list of names, fax numbers, e-mail addresses, or addresses of entities served]

This the _____ day of ______, 20___.

______

[insert attorney’s name, office address,

telephone number, and bar number]