UNITED STATES BANKRUPTCY COURT
EASTERN DISTRICT OF NEW YORK
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In the Matter of
                                        Chapter 7
     HUGO M. MOSQUEIRA and              Case No. 803-80743-478
NERI MOSQUEIRA,

                   Debtors.             NOTICE OF MOTION
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     PLEASE TAKE NOTICE that upon the annexed affirmation of Steven B.
Sheinwald, dated July 21, 2003 and upon all prior proceedings, the
undersigned will move this Court before the Honorable Dorothy Eisenberg,
at the Long Island Federal Courthouse, 290 Federal Plaza, Room 760,
Central Islip, New York, on the 12th day of August 2003, at 10:00 a.m. or
as soon thereafter as counsel can be heard, for an order:
(a) pursuant to 11 U.S.C. Sections 363(b) and (f) and Bankruptcy Rule
6004, authorizing the trustee to sell real property located at 10
Altamont Avenue, Sea Cliff, New York, free and clear of liens and
encumbrances, which liens shall attach to the proceeds of sale, for the
sum of $330,000.00;
(b) authorizing the trustee to disburse sufficient funds out of the
proceeds of sale to satisfy the liens which encumber the subject property
without further order of the Court;
(c) fixing the compensation of Realty Experts, Inc., as real estate
broker to the trustee in the aggregate sum of $14,850.00 and authorizing
the trustee to disburse the compensation awarded to the real estate
broker without further order of the Court;
(d) pursuant to 11 U.S.C. Section 105(a), authorizing the trustee to pay
all reasonable and necessary closing costs out of the proceeds of sale
without further order of the Court;
(e) directing the debtors to forthwith vacate the subject premises and to
remove all of their personal belongings; and
(f) for such other and further relief as this Court may deem just and
proper.     
     PLEASE TAKE FURTHER NOTICE that opposing papers, if any, to  the
relief requested by the trustee should be in writing, shall be filed with
the Clerk of the Bankruptcy Court, and served upon KIRSCHENBAUM &
KIRSCHENBAUM, P.C., Attorneys for the Trustee, 200 Garden City Plaza,
Garden City, New York, 11530, Attention: Steven B. Sheinwald, Esq. so as
to be actually be filed with the Clerk and received by the Trustee's
counsel no later than noon on August 7, 2003.
Dated: Garden City, New York     
       July 21, 2003

                            KIRSCHENBAUM & KIRSCHENBAUM, P.C.
                            Attorneys for the Trustee


                           
By:______________________________                                    
STEVEN B. SHEINWALD, ESQ.                                          200
Garden City Plaza                                              Garden
City, NY  11530                              (516) 747-6700