In response to a motion for relief from the automatic stay, Debtor contended that the bankruptcy petition filed on his behalf by a third person pursuant to a power of attorney given orally was filed prior to the foreclosure sale, making the foreclosure sale a nullity. HELD: (1) the bankruptcy petition was filed after the auction, and (2) without reaching the issue of whether a bankruptcy case could be instituted pursuant to a power of attorney, a written power of attorney is required to constitute a third party an attorney in fact.