Neither party has asked the Court to apply the definition supplied by section 522(f)(4) in this dispute. Ultimately, the Court need not decide whether section 522(f)(4) should somehow inform the meaning of “household goods” under the Maine exemption statute, which was enacted prior to 2005. Case 19-10320 Doc 48 Filed 01/10/20 Entered 01/10/20 14:59:49 Desc Main Document Page 7 of 9 - 8 - (concluding, under the Texas home furnishings exemption, that “to the extent the Artwork is actually used to furnish the Debtors’ home and is not being held for investment purposes, it may be claimed as exempt”); In re Bushey, 559 B.R. 766, 780 (Bankr. D.N.M. 2016) (allowing exemption in “wall art” under New Mexico’s exemption for “furniture” where there was no evidence that art was used for any purpose other than debtor’s personal use in decorating his home); Lucas v. ITT Fin. Servs. (In re Lucas), 77 B.R. 242, 246 (B.A.P. 9th Cir. 1987) (affirming trial court’s conclusion that certain decorative figurines were exempt as “household property” under California statute).

513 F.3d at 215. The case involved “a question of first impression in this circuit: the statutory interpretation of the newly enacted homestead exemption cap, 11 U.S.C. § 522(p)(1). . . .” Id. That statute, by its express terms, addresses limitations on a debtor’s ability to claim homestead 26 R4: 502, Docket No. 51 at p. 11.

By interaction of federal bankruptcy law and state law, debtors domiciled in New York may exempt from their estate, inter alia, interests in “a local public assistance benefit.” DCL § 282(2)(a); see also 11 U.S.C. § 522(b) (allowing States to define for their residents which property is exempt from the bankruptcy estate). Although neither the Debtor and Creditor Law nor the General Construction Law defines that phrase, the text, purpose, and legislative history of these laws and the rent stabilization laws confirm that rent stabilization rights qualify under DCL § 282(2)(a) as “assistance” provided to a “local” population by a “public” authority.

CONCLUSION Based on the foregoing, Defendants/Creditor request this Court grant its Motion to Dismiss and deny Plaintiff’s/Debtor’s request for relief under Sections 547 and 522.

17 (Pennymac) Notice of Hearing Motion to Avoid Judicial Lien - 3 SHOEMAKER & DART, P.S., INC. 6706 24th Street W, Suite A Tacoma, WA 98466 (253) 365-6363 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Considering the debtors’ $46,656.83 exemption available under 11 USC §522(d)(1), the sum total of all unavoidable liens against the property exceeds the value of the debtors’ interest in said property, thereby impairing the debtors’ lawful exemption. * Unavoidable liens $ 221,143.17 * 11 USC §522(d)(1)exemption 46,656.83 $ 267,800.00 WHEREFORE, debtors request the entry of an Order Avoiding the Lien of PHYSICIANS AND DENTISTS CREDIT BUREAU, INC. dba P&D COLLECTION SERVICES and providing that such lien shall not survive this bankruptcy proceeding or affix to or remain enforceable against the interest of the debtors in any of the aforementioned property following the conclusion of this case.

It also contravenes the purpose of Section 522(b)(3)(A) of the Bankruptcy Code, which permits debtors to retain property that is exempt under applicable state law, and Section 5201 and Section 282, which work jointly to exempt property that is not subject to process by non-bankruptcy creditors.

Property No. 1 Creditor's Name: Exeter Finance Corp Describe Property Securing Debt: 2013 Ford Escape Property will be (check one): Surrendered Retained If retaining the property, I intend to (check at least one): Redeem the property Reaffirm the debt Other. Explain (for example, avoid lien using 11 U.S.C. § 522(f)). Property is (check one): Claimed as Exempt Not claimed as exempt PART B - Personal property subject to unexpired leases.

(Amount subject to adjustment on 4/1/13, and every three years thereafter with respect to cases commenced on or after the date of adjustment.)11 U.S.C. §522(b)(2) 11 U.S.C. §522(b)(3) Description of Property Specify Law ProvidingEach Exemption Value of Claimed Exemption Current Value of Property Without Deducting Exemption continuation sheets attached to Schedule of Property Claimed as Exempt SCHEDULE C - PROPERTY CLAIMED AS EXEMPT Software Copyright (c) 1996-2010 - Best Case Solutions - Evanston, IL - www.bestcase.com Best Case Bankruptcy 0 Checking, Savings, or Other Financial Accounts, Certificates of Deposit Checking Account with Chase Bank 300.00Ind. Code § 34-55-10-2(c)(3) 300.

(Amount subject to adjustment on 4/1/16, and every three years thereafter with respect to cases commenced on or after the date of adjustment.)11 U.S.C. §522(b)(2) 11 U.S.C. §522(b)(3) Description of Property Specify Law ProvidingEach Exemption Value of Claimed Exemption Current Value of Property Without Deducting Exemption continuation sheets attached to Schedule of Property Claimed as Exempt SCHEDULE C - PROPERTY CLAIMED AS EXEMPT Software Copyright (c) 1996-2013 - CCH INCORPORATED - www.bestcase.com Best Case Bankruptcy 0 Checking, Savings, or Other Financial Accounts, Certificates of Deposit RFCU 100.00GCA § 44-13-100(a)(6) 100.

(Amount subject to adjustment on 4/1/13, and every three years thereafter with respect to cases commenced on or after the date of adjustment.)11 U.S.C. §522(b)(2) 11 U.S.C. §522(b)(3) Description of Property Specify Law ProvidingEach Exemption Value of Claimed Exemption Current Value of Property Without Deducting Exemption continuation sheets attached to Schedule of Property Claimed as Exempt SCHEDULE C - PROPERTY CLAIMED AS EXEMPT Software Copyright (c) 1996-2011 - CCH INCORPORATED - www.bestcase.com Best Case Bankruptcy 1 Cash on Hand Cash on Hand 50.00C.C.P. § 703.