MOW 4004-4 (08/07)

UNITED STATES BANKRUPTCY COURT

WESTERN DISTRICT OF MISSOURI

In Re: )

) Case No.

Debtor(s) )

**DEBTOR'S MOTION FOR ENTRY OF CHAPTER 13 DISCHARGE DUE TO PLAN
COMPLETION AND NOTICE OF DEADLINE AND OPPORTUNITY TO OBJECT**

Comes now the debtor and moves for entry of an Order of Discharge for
which the debtor is eligible under all applicable Bankruptcy laws and
rules.

The debtor has completed, after the filing of this case, the Personal
Financial Management course required by 11 USC § 1328 (g)(1) and has
filed the requisite certification (Official Form 23).

Pursuant to 11 USC § 1328 (f), the debtor has not received a discharge
in a case filed under chapter 7, 11, or 12 in the 4-year period
preceding the date of the order for relief under this chapter and has
not received a discharge in a case filed under chapter 13 in the 2-year
period preceding the date of such order.

If the debtor has claimed a homestead exemption in excess of \$125,000,
there is no proceeding pending in which the debtor may be found guilty
of a felony as described in 11 USC § 522(q)(1)(A) and the debtor is not
liable for a debt for the kind described in 11 USC § 522(q)(1)(B).

Pursuant to 11 USC § 1328(a), if the debtor has a Domestic Support
Obligation, all amounts payable under any judicial or administrative
order or by statute for domestic support obligations that were due on or
before the date upon which this certification was signed, including all
payments due under the plan for amounts due before the petition was
filed, have been paid. The name and address of each holder of a Domestic
Support Obligation is as follows:

Name Address

\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_
\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_
\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

The debtor's most recent/current address is:

\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

The name and address of debtor's most recent/current employer/income
source is:

\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

WHEREFORE, the debtor respectfully, moves this Court to enter a Chapter
13 Discharge.

Date: \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_
\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_
Debtor/Debtor's Attorney

**NOTICE OF OPPORTUNITY AND DEADLINE TO OBJECT TO MOTION FOR ENTRY OF
CHAPTER 13 DISCHARGE DUE TO PLAN COMPLETION**

PLEASE TAKE NOTICE THAT WITHIN TWENTY (20) DAYS AFTER THE DATE OF THIS
NOTICE you must file and serve a written objection to the motion. The
objection must be filed electronically with the Bankruptcy Court at
[www.ecf.mowb.uscourts.gov.]{.underline} If you are a pro se creditor,
you may file a written objection with the Clerk, United States
Bankruptcy Court, Western District of Missouri, 400 E. 9^th^ Street,
Room 1510, Kansas City, MO 64106. Debtor's attorney and trustee will
receive electronic notice when the objection is filed. If the debtor is
pro se, you must serve your objection on the debtor.

IF YOU FAIL TO FILE A TIMELY OBJECTION, THE MOTION MAY BE GRANTED BY THE
COURT WITHOUT A HEARING. The court may grant the motion without a
hearing if the objection filed states inadequate grounds for denial.

Date:
\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_
Debtor/Debtor's Attorney

**CERTIFICATE OF SERVICE**

I hereby certify that a copy of the foregoing Motion and Notice has been
served by first class mail on all creditors and parties requesting
notice.

Date: \_\_\_\_\_\_\_\_\_\_\_\_
\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_
Debtor/Debtor's Attorney

Instructions: Fill in all required information and serve on all
creditors.

ECF Event: Bankruptcy\>Motions/Applications/Requests\>Chapter 13
Discharge