In re Vertullo, 593 B.R. 92 (Bankr. D. N.H. 2018) –

A mortgagee that sold a chapter 13 debtor’s home in a prepetition foreclosure auction but had not yet recorded a foreclosure deed sought relief from the automatic stay in order to evict the debtor. In the meantime, the debtor filed a plan that proposed to cure the prepetition mortgage defaults and continue payments. The bankruptcy court had to decide whether the mortgagee had completed the foreclosure sale within the meaning of the Bankruptcy Code and whether the debtor retained sufficient interest in the property to allow her to exercise a right to cure the mortgage defaults.