Attached is the format I used to submit a Motion to Strip Lien and Determine Secured Status. This was used to successfully strip a second lien from a primary residence.
On the Plan, the Claim for the second lien was noted as "Lien Strip".
The Lender's Attorney did not respond to the Motion within the 30-day negative notice period.
You will want to see if negative noticing is allowed by local rule of YOUR DISTRICT AND JUDGE! Negative noticing isn't always available.
Also, some District do not allow stripping by Motion. In some District, stripping can only be done by Adversarial Proceedings.
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justbroke started a blog post Lien Stripping -- Sample DocumentLien Stripping -- Sample Document
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Many people will just get a Competitive Market Analysis (CMA) from a Real Estate Agent, or run some on-line Electronic Appraisal, or worse... GUESS!!!
None of those methods are strong evidence for lien stripping. Only a Professional Appraiser performing a full appraisal trumps all them. Just get a full-appraisal and save headaches and multiple hearings!
My motion went un-opposed (with negative noticing) and the Bank never even challenged my valuation.
In my case, I'm paying 2% to unsecured creditors.
What your lawyer told you is false, a slight misunderstanding or an oversimplification.