How would you go about a motion to lift stay for the following scenario:

Bankruptcy Matter for Automotive Financing, Inc. (File No. 1111111111)

Dear A. Paralegal,

We represent Automotive Financing, Inc. (AFI), located at 239 Main St. in Capitol City. On September 1, 2011, Mr. Abelard R. Mendoza purchased a new 2011 Cadillac Deville from Rogers Cadillac on Highway 11 Bypass. AFI financed the purchase. The original loan amount was $30,000 and the current balance is $25,000. The book value on the vehicle is $23,000. The promissory note and security agreement that Abelard signed is dated September 1, 2011, and our lien is properly noted on the title to the vehicle.

One week ago, today Mr. Mendoza filed a Chapter 7 bankruptcy case. His notice of intent suggests he does not plan to redeem the vehicle or seek a reaffirmation agreement with AFI. I spoke with his lawyer who advised that Mr. Mendoza is willing to surrender the vehicle to us.

I would like you to do a motion to lift stay on the vehicle on behalf of AFI per 362(d) of the Code and FRBP 4001 on the grounds debtor has no equity in it and it is not needed for any reorganization. We could wait forty-five days after the first meeting of creditors when the stay will automatically expire, pursuant to 521(a)(6), but I don't want to wait that long to regain possession of the car. AFI has a buyer arranged who will pay the full book value for it.