Myrline Rivera
11 U.S.C. § 722
- Movant is the debtor in the above-captioned chapter 7 case. This matter is a core matter.
- Among the dischargeable consumer debts listed in the petition filed herein was a loan from Bridgecrest Credit Company secured by Movant‘s 2020 Nissan Pathfinder with the VIN number 5N1DR2CM2LC613222.
- The automobile has been claimed as exempt under
11 U.S.C. § 522(d)(2) , and is used by Movant for personal and family purposes. - The Kelley Blue Book Private Party valuation for a 2020 Nissan Pathfinder with approximately 92,013 miles in the 17851 ZIP code is $12,236.00. A copy of that valuation is attached as Exhibit A.
Attached as Exhibit B is an estimate that shows that to make certain repairs to the property would cost $2,549.96. - Thus, the net replacement value of the vehicle considering its age and condition is $9,686.04.
- Movant wishes to redeem the vehicle pursuant to
11 U.S.C. § 722 .
WHEREFORE, Movant prays this Court order Bridgecrest Credit Company to remove and mark satisfied any encumbrance or security interest in Movant‘s vehicle upon payment to Bridgecrest Credit Company of $9,686.04.
Date: November 25, 2025
s/ Carlo Sabatini
Carlo Sabatini, PA 83831
Attorney for Movant
Sabatini Law Firm, LLC
216 N. Blakely St.
Dunmore, PA 18512
Phone (570) 341-9000
Facsimile (570) 504-2769
Email ecf@bankruptcypa.com