ComplaintMy wife and i filed for CH XXXX in XX/XX/XXXX, XXXX XXXX in Arizona. One of our creditors was " Citibank '' wherein we proposed to treat CitiBank 's claim, which was secured by a second deed of trust on our XXXX at XXXX XXXX XXXX XXXX. XXXX AZ XXXX that had a value of less than the amount owing on the first deed of trust, as an unsecured claim which would share pro rata with other unsecured claimants in a {$50000.00} dividend ( the " Dividend '' ). ( See Plan pages XXXX, and XXXX. ) As evidenced by the Certificate of Service on file in the case, the Plan was sent out to CitiBank and other creditors on XX/XX/XXXX. 
The Plan was approved and confirmed by the Bankruptcy Court on XX/XX/XXXX. A copy of the court 's Order is enclosed. 
Since the Plan 's confirmation, we have fully distributed to unsecured creditors, including CitiBank, all amounts required in the Plan ; and a final decree has been entered in the bankruptcy case. All of the Dividend payments have been accepted. In particular, a total of {$3600.00} has been paid to and accepted by CitiBank on account of its claim. 
Upon its confirmation, the Plan constituted a new contract with us and our creditors that superseded the old contracts. Section XXXX of the Plan provides that " the rights afforded under this Plan and the treatment of Claims under this Plan shall be in exchange for and in complete satisfaction, discharge and release of all Claims .... '' CitiBank received its Plan payments and no longer has any Claim against us and therefore must release its lien. 
We received " Notice of Final Decree and Order Closing Case XX/XX/XXXX. Since that date, we have written, phoned, faxed and mailed dozens of requests for CitiBank requesting to release its deed of trust against the Property, recorded on XX/XX/XXXX in the office of the XXXX County Recorder at number XXXX ( the " Deed of Trust '' ) ; but it has thus far failed to do so. Even our attorney has written, but to no avail. 
However, they refuse to take any action. We have an urgent issue necessitating the sale of this property immediately, but are unable to do so because of the lien Citibank refuses to remove. And now, we have received a letter asking for a " Voluntary " payment of $ XXXXin order to release the lien on the property. ( enclosed ) If unable to have this removed immediately, we will be totally financially destroyed after meeting all of our financial responsibilities under the Bankruptcy court requirements and obligations. 
Thank you for your Assistance, XXXX XXXX 
