UNITED STATES BANKRUPTCY COURT

EASTERN DISTRICT OF VIRGINIA

Norfolk Division

In Re: TROY ANTHONY EATON, SR., and

 APRIL JULY EATON, Case No.:15-71583-SCS 

 Debtors. Chapter 7

LAWRENCE H. GLANZER, TRUSTEE,

 Plaintiff,

vs.

APN: 15-07067-SCS

TROY ANTHONY EATON, SR., and

APRIL JULY EATON,

 Defendants.

ANSWER TO COMPLAINT OBJECTING TO DISCHARGE

COMES NOW, Troy Anthony Eaton, Sr. and April July Eaton,

Debtors, by counsel and for their Answer to Complaint Objecting to

Discharge state as follows:

1) The Debtors admit paragraphs 1, 2, 3, 4, 5, 6, 7, 8, 9,

10, 11, 12, 13 and 14. 

2) The Debtors admit paragraph 15 in so far as the Debtors 

did not amend Schedules or Statement of Financial Affairs before

Trustee complaint but denied in so far as Debtors have subsequently

amended the same.

Ronald J. Berg, VSB#7229

BERG & ASSOCIATES, P.C.

700 Newtown Road, Ste 110

Norfolk, Virginia 23502

Phone (757) 461-5557

Fax (757) 461-4021

Case 15-07067-SCS Doc 7 Filed 08/26/15 Entered 08/26/15 16:50:26 Desc Main

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3) In regards to paragraph 16 already answered herein.

4) In regards to paragraph 17 the Debtors had prepaid cards

which they failed to identify as checking accounts.

5) Paragraphs 18, 19, and 20 are denied as to intent to 

conceal as any balances contained in the prepaid cards as proceeds

were otherwise reported as earnings or tax refunds. 

6) The Debtors admit paragraph 21.

7) The Debtors deny paragraph 22 as to intent.

8) The Debtors admit paragraph 23 as to time and dates but 

same denied as to intent.

9) In regards to paragraph 24 already answered herein.

10) The Debtors deny paragraphs 25, 26, and 27 as to intent.

11) In regards to paragraph 28 already answered herein.

12) The Debtors admit paragraph 29.

13) The Debtors deny paragraphs 30 and 31 in that no 

intentional refusal existed and the Debtors acknowledged at the 341

Hearing prepaid card references, and post complaint have amended

their petition.

WHEREFORE, the Debtors pray that the Trustees Complaint

Objecting to Discharge on count one concealment of property, and

count two false oath, and count three withholding information, be

Ronald J. Berg, VSB#7229

BERG & ASSOCIATES, P.C.

700 Newtown Road, Ste 110

Norfolk, Virginia 23502

Phone (757) 461-5557

Fax (757) 461-4021

Case 15-07067-SCS Doc 7 Filed 08/26/15 Entered 08/26/15 16:50:26 Desc Main

 Document Page 2 of 3
dismissed and denied in that the actions of the Debtors do not

justify denial of affirmative relief pursuant to 11 U.S.C.

§727(a)(2), 11 U.S.C. §727(a)(4)(A) and 11 U.S.C. §727(a)(6).

TROY ANTHONY EATON, SR.

APRIL JULY EATON

BY: /s/ Ronald J. Berg 

Of Counsel

CERTIFICATE OF MAILING

I, the undersigned, hereby certify that on this 26th day of

August, 2015, I mailed/electronically mailed a true copy of the for

going Answer to Complaint Objecting to Discharge to Kenneth N.

Whitehurst, III, Esquire, Office of the United States Trustee, 200

Granby Street, Room 625, Norfolk, Virginia 23510, Lawrence H.

Glanzer, Chapter 7 Trustee, 580 East Main Street, Suite 300,

Norfolk, Virginia 23510, to Troy Anthony Eaton, Sr. And April July

Eaton, Debtors, at 3496 Smokey Chamber Drive, Virginia Beach,

Virginia 23462; and to all creditors and parties interest in the

above referenced case.

 /s/ Ronald J. Berg 

Ronald J. Berg 

Ronald J. Berg, VSB#7229

BERG & ASSOCIATES, P.C.

700 Newtown Road, Ste 110

Norfolk, Virginia 23502

Phone (757) 461-5557

Fax (757) 461-4021

Case 15-07067-SCS Doc 7 Filed 08/26/15 Entered 08/26/15 16:50:26 Desc Main

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