MOTION TO MODIFY CHAPTER 13 PLAN

Pursuant to 11 U.S.C. Section 1329

UNITED STATES BANKRUPTCY COURT

[DISTRICT NAME]

In re:

[DEBTOR NAME(S)],

Debtor(s).

Case No.: _________________
Chapter: 13

MOTION TO MODIFY CONFIRMED CHAPTER 13 PLAN

[DEBTOR NAME(S)] ("Debtor(s)"), by and through undersigned counsel, hereby move(s) this Court pursuant to 11 U.S.C. Section 1329 for an Order approving a modification to the Debtor(s)' Confirmed Chapter 13 Plan and state(s):

I. CASE BACKGROUND

1. The Debtor(s) filed a voluntary petition under Chapter 13 on [DATE].

2. The Chapter 13 Plan was confirmed on [DATE].

3. The Confirmed Plan provides for:
   - Monthly payment: $[AMOUNT]
   - Plan length: [NUMBER] months
   - Unsecured dividend: [___]%

4. Payments to date: $[AMOUNT] over [NUMBER] months

5. Remaining payments: [NUMBER] months totaling approximately $[AMOUNT]

II. GROUNDS FOR MODIFICATION

The Debtor(s) request modification of the Confirmed Plan due to the following changed circumstances (check all that apply):

A. Income Changes

☐ Decrease in Income

Reason for decrease:
☐ Job loss / Layoff - Date: __________
☐ Reduced hours
☐ Demotion / Pay cut
☐ Disability / Illness
☐ Retirement
☐ Other: _________________________________

☐ Increase in Income

Reason for increase:
☐ New employment
☐ Promotion / Raise
☐ Additional employment
☐ Other: _________________________________

B. Expense Changes

☐ Increase in Necessary Expenses

Reason for increase:
☐ Medical expenses
☐ Housing cost increase
☐ Child care
☐ Special needs dependent
☐ Other: _________________________________

☐ Decrease in Expenses

C. Debt/Claim Changes

☐ Secured Debt Paid Off
- Creditor: _________________________________
- Collateral: _________________________________
- Payment freed: $[AMOUNT] per month

☐ Change in Claim Amounts
- Creditor: _________________________________
- Scheduled: $_____________ Allowed: $_____________

☐ New Debt to be Added (with Court approval)
- Creditor: _________________________________
- Purpose: _________________________________
- Amount: $_____________
- Monthly payment: $_____________

D. Other Circumstances

☐ Divorce / Separation
☐ Death of spouse
☐ Natural disaster
☐ Vehicle breakdown requiring replacement
☐ Home repair emergency
☐ Other: _________________________________

III. PROPOSED MODIFICATION

A. Change in Payment Amount

B. Change in Plan Duration

☐ Extend plan term
- Current end date: _____________
- Proposed end date: _____________
- Additional months: _____________

☐ Shorten plan term
- Current end date: _____________
- Proposed end date: _____________
- Months reduced: _____________

Note: Plan may not exceed 60 months from date of first payment (currently: [DATE]).

C. Change in Treatment of Claims

☐ Modify secured claim treatment
☐ Modify priority claim treatment
☐ Modify unsecured dividend

D. Complete Proposed Terms

IV. UPDATED BUDGET ANALYSIS

A. Current Monthly Income

B. Current Monthly Expenses

C. Disposable Income Calculation

V. COMPLIANCE WITH SECTION 1325

The proposed Modified Plan continues to satisfy the confirmation requirements:

A. Good Faith - 11 U.S.C. Section 1325(a)(3)

☐ This modification is proposed in good faith due to genuine changed circumstances

B. Best Interests Test - 11 U.S.C. Section 1325(a)(4)

☐ Unsecured creditors will receive at least as much as in a Chapter 7 liquidation
- Liquidation value: $_____________
- Total to unsecured under modified plan: $_____________

C. Feasibility - 11 U.S.C. Section 1325(a)(6)

☐ Debtor(s) can make all modified plan payments
- Disposable income: $_____________
- Proposed payment: $_____________
- Cushion: $_____________

D. Plan Term - 11 U.S.C. Section 1329(c)

☐ Modified plan will not extend beyond 60 months from first payment date
- First payment date: _____________
- Maximum end date: _____________
- Proposed end date: _____________

VI. SUPPORTING DOCUMENTATION

The following are attached as exhibits:

☐ Exhibit A: Updated Schedule I (Income)
☐ Exhibit B: Updated Schedule J (Expenses)
☐ Exhibit C: Pay stubs (last 60 days)
☐ Exhibit D: Documentation of changed circumstances
☐ Exhibit E: Chapter 13 Trustee payment history
☐ Exhibit F: Proposed Modified Plan
☐ Exhibit G: Comparison of current vs. modified plan

VII. RELIEF REQUESTED

WHEREFORE, the Debtor(s) respectfully request that this Court:

1. Approve the proposed modification to the Confirmed Chapter 13 Plan;

2. Modify the monthly plan payment from $[CURRENT] to $[PROPOSED] effective [DATE];

3. [OTHER SPECIFIC RELIEF];

4. Grant such other relief as the Court deems just and proper.

Dated: ____/____/________

Respectfully submitted,

_________________________________
[ATTORNEY NAME]
[STATE BAR NUMBER]
[FIRM NAME]
[ADDRESS]
[TELEPHONE]
[EMAIL]
Attorney for Debtor(s)

NOTICE OF MOTION

PLEASE TAKE NOTICE that the above Motion to Modify Confirmed Chapter 13 Plan will be heard on:

Date: _________________________________
Time: _________________________________
Location: _________________________________

Objections must be filed and served no later than [DATE] (as required by local rules).

CERTIFICATE OF SERVICE

I certify that on [DATE], I served the foregoing Motion on:

☐ Chapter 13 Trustee
☐ Office of the U.S. Trustee
☐ All creditors (via CM/ECF and/or mail per matrix)

_________________________________
[ATTORNEY NAME]

Template Version 1.0 - Updated January 2026
References: 11 U.S.C. Sections 1325, 1329; Fed. R. Bankr. P. 3015