This is what I wrote: any comments?
OBJECTION TO DEERE AND COMPANY’S MOTION TO LIFT STAY
COMES NOW, xxxxxxxxxxxx, affirming the following to be true and correct and showing the Court as follows:
1. I am not represented by an attorney in connection with this Objection.
2. There is no intention to mislead, hinder, delay or defraud any creditor or the Court in this matter.
3. The property in question is necessary to complete the Chapter 12 plan.
4. Said Plan has been agreed upon to the satisfaction of all parties and is pending confirmation.
5. Total value of property in question as declared by Deere and Company is $194,000.00.
6. Total contract payoff balance as declared by Deere and Company as of June 23, 2010 was $149,919.56.
7. Deere is adequately protected.
8. No request for inspection has been refused.
9. The property has been inspected twice: once during wheat harvest, June/July 2008, and again after fall harvest in early winter 2009.
10. Property may be viewed and inspected during regular business hours at xxxxxxxxxxxxxxxxxxxx at the request of John Deere.
11. Property is fully insured by Farmer’s Alliance. Agent may be contacted for confirmation at xxxxxxxxxxxxxxxxxxxxxxxxxxx Phone xxxxxxxxxxxxxxxx.
12. I am competent to complete the Chapter 12 Plan and Settlement agreement as proposed and fully intend to do so upon Plan confirmation.
13. All payments will be made as agreed once Chapter 12 Plan is confirmed.
14. In the event that the Motion to RESTORE THE CASE TO CHAPTER 12 AND CONFIRM THE REORGANIZATION PLAN is denied, Property is necessary to complete fall harvest and fulfill obligations in Chapter 7.
I, Edward William Bange, herewith request that the Court deny DEERE AND COMPANY’S MOTION FOR RELIEF FROM AUTOMATIC STAY; and that the Court provide such further relief as to the Court seems just, fair and equitable.