In re Quade, 482 B.R. 217

EEI has a registered state-court judgment against Debtor for $884,056.55.
EEI served third-party citations and a garnishment to seek turnover of assets.
Debtor’s pre-petition property included Merrill Lynch accounts (Roth IRA, regular IRA) and other personal property.
Debtor filed Chapter 7 on July 3, 2012, triggering the automatic stay and stayed state-court proceedings.
State courts issued turnover orders and liens pre-petition; EEI seeks stay relief and lien avoidance.
Exemptions claimed by Debtor under Illinois law include homestead, retirement accounts, and other property; EEI challenges some exemptions.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Debtor may avoid liens under §522(f).	Quade; Debtor's exemptions impair liens.	EEI; exemptions waived/limited due to state orders.	Debtor may avoid certain judicial liens to the extent they impair exemptions.
Whether EEI is entitled relief from stay given lack of equity.	EEI; Debtor lacks equity in property, so stay should lift.	Quade; exemptions and ownership prevent lack of equity from establishing stay relief.	Relief from stay granted to EEI to extent liens pursue nonexempt assets; otherwise denied for exempt assets.
Effect of Turnover Order on Debtor's estate and ownership.	EEI asserts turnover reduced Debtor’s rights prepetition.	Debtor; turnover did not divest estate interests prior to filing.	Turnover order did not transfer ownership; property remained estate property on petition date.

In re Johnson, 215 B.R. 381 (Bankr.N.D.Ill.1997) (citation service creates a lien; securing property)
In re Vitreous Steel Prods. Co., 911 F.2d 1223 (7th Cir.1990) (summary nature of stay relief hearings)
In re Moore, 450 B.R. 849 (Bankr.N.D.Ind.2011) (equity and valuation in stay relief analysis)
Crowell v. Porayko (In re Porayko), 443 B.R. 419 (Bankr.N.D.Ill.2010) (waiver of exemptions; bankruptcy exemptions can be pursued postpetition)