Kenneth N. Whitehurst, III, Esq., AUST, VSB No. 48919

Cecelia Ann Weschler, Esq., VSB No. 28245

Nicholas S. Herron, Esq., NJSB No. 03007-2008, PASB No. 208988

Office of the United States Trustee

200 Granby Street, Room 625

Norfolk, VA 23510

(757) 441-6012

UNITED STATES BANKRUPTCY COURT

EASTERN DISTRICT OF VIRGINIA

NORFOLK DIVISION

In re:

Jeremey R. Lynch

Lacresha Blythe,

Debtors.

 Case No. 15-74476/SCS

 Chapter 7

Judy A. Robbins

U.S. Trustee for Region Four, 

Plaintiff

APN No._____________ 

v. 

Monique Sherida Fields

Defendant.

COMPLAINT SEEKING IMPOSITION OF FINES, DISGORGEMENT OF 

COMPENSATION, PERMANENT INJUNCTION

FROM FURTHER VIOLATIONS OF 11 U.S.C. § 110 AND FROM ACTING

AS A BANKRUPTCY PETITION PREPARER AND OTHER RELIEF

Judy A. Robbins, United States Trustee for Region Four, by counsel, brings this 

complaint against defendant, Monquie Sherida Fields, pursuant to 11 U.S.C. §110, and states: 

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JURISDICTION AND VENUE

1. This Court has jurisdiction over this Adversary Proceeding pursuant to 28 U.S.C.

§§ 157 and 1334, 11 U.S.C. §§ 105(a) and 110(j)(1), (2)(A) and (2)(B), and 28 U.S.C. §157(a). 

This Adversary Proceeding arises in a case under Title 11 of the United States Code and is a core 

proceeding pursuant to 28 U.S.C. § 157(b)(2)(A).

2. Venue is proper in this Court pursuant to 28 U.S.C. § 1409.

PARTIES

3. Plaintiff, Judy A. Robbins, is the United States Trustee for Region Four, which 

includes the Eastern District of Virginia, and is duly appointed under 28 U.S.C. § 581(a)(4).

4. The debtors, Jeremey R. Lynch and Lacresha Blythe, (“Lynch” and “Blythe”), are 

individuals residing in Carrollton, Virginia, in the Eastern District of Virginia, and are the 

debtors in this chapter 7 case.

5. The defendant, Monique Sherida Fields, (“Fields”), is an individual residing in 

Newport News, Virginia, and conducts business as a bankruptcy petition preparer within the 

Eastern District of Virginia. 

6. Fields is a “person, other than an attorney for the debtor or an employee of such 

attorney under the direct supervision of such attorney, who prepares for compensation a 

document for filing” and is a “bankruptcy petition preparer,” within the meaning of 11 U.S.C. § 

110.

7. Fields is not licensed to practice law in the Commonwealth of Virginia and she is 

not admitted to practice before this Court.

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STATEMENT OF FACTS

8. Monique Fields has been actively preparing bankruptcy petitions and documents 

for filing before the United States Bankruptcy Court for the Eastern District of Virginia. 

9. Fields has prepared bankruptcy petitions and documents for filing in at least four

cases which have been closed or are currently pending before the Court. 

10. Fields prepared documents for filing in the following cases:

Name Case No. Chapter Petition Date Payment to 

Fields

Status/Disposition

Lavene A. 

Hall

15-51352-SCS 7 October 13, 

2015

$140 Pending/Discharged

Teneshia K. 

Aaron

15-51392-FJS 7 October 20, 

2015

$140 Closed/Discharged

Reginald D. 

Lucas

15-51661-FJS 7 December 17, 

2015

$550 Pending

Jeremy 

Lynch and 

Lacresha 

Blythe

15-74476-SCS 7 December 31, 

2015

$540 Pending

11. Fields has violated at least one or more provisions under Section 110 in preparing

documents for the debtors in each of the above listed cases. 

12. On information and belief, Fields has acted, and continues to act as a bankruptcy

petition preparer and engages in the unauthorized practice of law in other cases not specified. 

Jeremy Lynch and Lacresha Blythe Case No. 15-74476

13. On December 31, 2015, Lynch and Blythe filed a joint voluntary Chapter 7 

bankruptcy petition with the assistance of Fields.

14. Lynch and Blythe relied on Fields to prepare the schedules, statements, and 

petition in this case and she prepared them.

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15. Lynch and Blythe paid $540 to Fields for her services as a bankruptcy petition 

preparer.

16. Fields did not provide Lynch and Blythe a copy of Official Form 119 (Bankruptcy 

Petition Preparer’s Notice, Declaration, and Signature) prior to receiving payment.

17. On December 31, 2015, Lynch and Blythe filed an Application to Have the 

Chapter 7 Filing Fee Waived.

18. Fields prepared the Application to Have the Chapter 7 Filing Fee Waived on 

behalf of Lynch and Blythe without identifying herself on the document either by name and/or 

identification number. 

19. Lynch and Blythe testified at their 341(a) hearing that they were not notified of 

the filing fee. 

20. Fields prepared a Homestead Deed for Lynch and Blythe to sign in an effort to 

exempt certain assets.

21. The Homestead Deed for Personal Property bears Fields’ information as the 

preparer of the document.

22. On February 4, 2016, the Homestead Deed for Personal Property was recorded 

with the Newport News Circuit Court Clerk.

23. Lynch and Blythe were advised by Fields that the Homestead Deed was necessary 

to protect their assets. Fields also advised them as to the dollar limits of the available 

exemptions.

24. Fields charged Lynch and Blythe a total of $540.00 for the preparation of their 

bankruptcy petition and required an initial deposit before beginning work.

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25. Lynch and Blythe paid the $540 in cash, but over three installment payments. The 

first payment was in the amount of $150. The second installment was paid in cash in the amount 

of $200. The third and final installment payment was paid in cash in the amount of $200. The 

receipts are filed as Exhibit “A”.

26. Fields failed to file with the petition a declaration disclosing the total amount of 

compensation received in connection with this petition as required under 11 U.S.C. § 110(h). 

27. Lynch and Blythe testified at their 341(a) hearing that Fields advised them about 

whether to continue to pay their vehicle payments and rental payments.

Reginald D. Lucas Case No. 15-51661

28. On December 17, 2015, Reginald D. Lucas (“Lucas”) filed a voluntary Chapter 7 

bankruptcy petition with the assistance and advice of Fields.

29. Lucas relied on Fields to prepare the schedules, statements and petition in this 

case and she prepared them.

30. Fields advised Lucas to file a bankruptcy petition to stop wage garnishments. 

31. Lucas paid $550 to Fields for her services as a bankruptcy petition preparer.

32. On December 16, 2015, Lucas signed a contract with Fields to perform 

bankruptcy preparation services. Page two, paragraph seven, reflects Fields’ fee of $550. A copy 

of the contract is filed as Exhibit “B”.

33. On or about December 16, 2015, Lucas gave Fields an initial deposit in the 

amount of $160.00 in cash.

34. Fields did not provide Lucas a copy of Official Form 119 (Bankruptcy Petition 

Preparer’s Notice, Declaration, and Signature) prior to receiving payment.

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35. On December 17, 2015, Lucas filed an Application to Have the Chapter 7 Filing 

Fee Waived.

36. Fields prepared the Application to Have the Chapter 7 Filing Fee Waived on 

behalf of Lucas without identifying herself on the document either by name and/or identification 

number. 

37. Fields prepared a Homestead Deed for Lucas to sign in an effort to exempt certain 

assets.

38. The Homestead Deed for Personal Property bears Fields’ information as the 

preparer of the document.

39. On January 13, 2016, the Homestead Deed for Personal Property was recorded 

with the Newport News Circuit Court Clerk.

40. December 31, 2015 was the deadline for Lucas to file the remaining schedules 

and statements, or his case would be dismissed. 

41. Fields refused to file the remaining documents until $390 (the balance of the 

$550) was received in full. 

42. On December 31, 2015, Fields assisted and advised Lucas in preparing a Motion 

to Extend Time which was filed with the Court that day.

43. On December 31, 2015, the Court issued an Order Granting Debtor’s Motion to 

Extend Time and extending the deadline to file the remaining documents to January 19, 2016.

44. Prior to the January 19, 2016 deadline, Lucas paid the remaining outstanding 

balance of $390 in cash to Fields.

45. On January 6, 2016, Lucas received the remaining documents to file with the 

Court from Fields. 

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46. Fields prepared Lucas’ exemptions, on Schedule C, without his input and decided 

which Virginia statutes to utilize.

47. Fields requested that Lucas not disclose the $550 paid to her for the petition 

preparing services, but rather report that he only paid $140. He declined her request to 

misrepresent the total amount of fees paid.

48. Fields advised Lucas that he should not pay either his rental payments or vehicle 

payments because the court did not like when a debtor preferred one creditor over the other. 

49. Lucas followed Fields’ advice and stopped making all vehicle payments to 

Bayport Credit Union.

50. On December 29, 2015, Bayport Credit Union filed a Motion for Relief from the 

Automatic Stay on the basis of non-payment. 

51. On January 26, 2016, the Court granted Bayport Credit Union’s Motion for Relief 

from the Automatic Stay.

Lavene A. Hall Case No. 15-51352

52. On October 13, 2015, Lavene A. Hall (“Hall”) filed a voluntary Chapter 7 

bankruptcy petition with the assistance and advice of Fields.

53. Hall relied on Fields to prepare the schedules, statements, and petition in this case

and she prepared them.

54. Hall paid $140 to Fields for her services as a bankruptcy petition preparer.

55. Fields did not provide Hall a copy of Official Form 119 (Bankruptcy Petition 

Preparer’s Notice, Declaration, and Signature) prior to receiving payment.

56. On October 13, 2015, Hall filed an Application to Have the Chapter 7 Filing Fee 

Waived. 

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57. On October 16, 2015, the Court entered an Order Granting Application for 

Waiver of Chapter 7 Filing Fee.

58. On October 23, 2015, the remaining schedules and statements were filed with the 

Court.

59. Fields prepared a Homestead Deed for Hall to sign in an effort to exempt certain 

assets.

60. The Homestead Deed for Personal Property bears Fields’ information as the 

preparer of the document. 

61. The Homestead Deed sought to protect assets in the total amount of $126,185.

62. On November 12, 2015, the Homestead Deed for Personal Property was recorded 

with the Hampton Circuit Court Clerk.

63. On January 12, 2016, David R. Ruby, the chapter 7 trustee, filed an objection to 

debtor’s claimed homestead exemptions.

64. On February 16, 2016, the objection was settled between David R. Ruby and 

debtor’s new counsel, Sherman Smith.

65. On February 19, 2016, the debtor filed a motion to convert to a Chapter 13.

Teneshia K. Aaron Case No. 15-51392

66. On October 20, 2015, Teneshia K. Aaron (“Aaron”) filed a voluntary Chapter 7 

bankruptcy petition with the assistance and advice of Fields.

67. Aaron relied on Fields to prepare the schedules, statements, and petition in this 

case and she prepared them.

68. Aaron paid $140 to Fields for her services as a bankruptcy petition preparer.

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69. Fields did not provide Aaron a copy of Official Form 119 (Bankruptcy Petition 

Preparer’s Notice, Declaration, and Signature) prior to receiving payment.

70. On October 20, 2015, Aaron filed an Application to have the Chapter 7 Filing Fee 

Waived. 

71. On October 26, 2015, the Court entered an Order Granting Application for 

Waiver of the Chapter 7 Filing Fee.

72. On November 2, 2015, the remaining schedules and statements were filed with 

the Court.

73. Fields prepared a Homestead Deed for Personal Property for Aaron to sign in an 

effort to exempt certain assets.

74. On November 18, 2015, the Homestead Deed for Personal Property was recorded 

with the Hampton Circuit Court Clerk.

75. Fields advised Aaron of the differences between a Chapter 7 and Chapter 13 

bankruptcy.

76. Fields selected the exemptions for property which Aaron claimed on Schedule C.

Count I

Violation of 11 U.S.C. § 110(b)(1)

77. Plaintiff repeats the allegations contained in Paragraphs 1 through 76 as if set 

forth herein.

78. Pursuant to section 110(b)(1) a bankruptcy petition preparer who prepares a 

document for filing must “sign the document and print on the document the preparer’s name and 

address.” 11 U.S.C. § 110(b)(1).

79. Fields failed to sign or print her name and address on the application to waive 

filing fees prepared on behalf of Lucas in violation of Section 110(b)(1).

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80. Fields failed to sign or print her name and address on the application to waive 

filing fees prepared on behalf of Lynch and Blythe in violation of Section 110(b)(1).

81. Under § 110(l)(1), a bankruptcy petition preparer “who fails to comply with any 

provision of subsection (b), (c), (d), (e), (f), (g), or (h) may be fined not more than $500 for each 

such failure.” 11 U.S.C. § 101(l)(1).

82. Fields’ failure to sign and print on the application to waive filing fees her name, 

address, and/or identification number on these filings warrants fines in the amount of $500 for 

each offense, for a total fine of $1,000.

Count II

Violation of 11 U.S.C. § 110(b)(2)

83. Plaintiff repeats the allegations contained in Paragraphs 1 through 82 as if set 

forth herein.

84. Pursuant to section 110(b)(2)(A), "before preparing any document for filing or 

accepting any fees from a debtor, the bankruptcy petition preparer shall provide to the debtor a 

written notice which shall be on an official form prescribed by the Judicial Conference of the 

United States in accordance with rule 9009 of the Federal Rules of Bankruptcy Procedures.” 11 

U.S.C. § 110(b)(2)(A).

85. A notice under 11 U.S.C. § 110(b)(2)(A) "(i) shall inform the debtor in simple 

language that a bankruptcy petition preparer is not an attorney and may not practice law or give 

legal advice; (ii) may contain a description of examples of legal advice that a petition preparer is 

not authorized to give, in addition to any advice that the preparer may not give by reason of 

subsection (e)(2); and (iii) shall (I) be signed by the debtor and, under penalty of perjury, by the 

bankruptcy petition preparer; and (II) be filed with any document for filing." 11 U.S.C. § 

110(b)(2)(B).

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86. Fields did not provide Lynch and Blythe a copy of Official Form 119 (Bankruptcy 

Petition Preparer’s Notice, Declaration, and Signature) prior to accepting fees for services and 

preparation of the petition in violation of § 110(b)(2).

87. Fields did not provide Lucas a copy of Official Form 119 (Bankruptcy Petition 

Preparer’s Notice, Declaration, and Signature) prior to accepting fees for services and 

preparation of the petition in violation of § 110(b)(2).

88. Fields did not provide Hall a copy of Official Form 119 (Bankruptcy Petition 

Preparer’s Notice, Declaration, and Signature) prior to accepting fees for services and 

preparation of the petition in violation of § 110(b)(2).

89. Fields did not provide Aaron a copy of Official Form 119 (Bankruptcy Petition 

Preparer’s Notice, Declaration, and Signature) prior to accepting fees for services and 

preparation of the petition in violation of § 110(b)(2).

90. Under § 110(l)(1), a bankruptcy petition preparer “who fails to comply with any 

provision of subsection (b), (c), (d), (e),(f), (g), or (h) may be fined not more than $500 for each 

such failure.” 11 U.S.C. § 101(l)(1).

91. Fields’ failure to adhere to the noticing requirements under § 110(b)(2) constitutes 

a violation and warrants sanctions in the amount of $500 per violation, for a total fine of $2,000.

Count III

Violation of 11 U.S.C. § 110(c)

92. Plaintiff repeats the allegations contained in Paragraphs 1 through 91 as if set 

forth herein.

93. Pursuant to section 110(c), a bankruptcy petition preparer is prohibited from 

preparing a document for filing without placing a number on the document which identifies the 

individual preparer. The identifying number – the social security number of the bankruptcy 

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petition preparer – must be placed after the bankruptcy petition preparer’s signature on any 

document the bankruptcy petition preparer prepares for filing. 11 U.S.C. § 110(c).

94. Fields failed to place an identifying number on the Application to Waive Chapter 

7 Filing Fees which she prepared in connection with the Luca case in violation of § 110(c).

95. Fields failed to place an identifying number on the Application to Waive Chapter 

7 Filing Fees which she prepared in connection with the Lynch and Blythe case in violation of § 

110(c).

96. Under § 110(l)(1), a bankruptcy petition preparer “who fails to comply with any 

provision of subsection (b), (c), (d), (e),(f), (g), or (h) may be fined not more than $500 for each 

such failure.” 11 U.S.C. § 101(l)(1).

97. Fields’ violation of subsection (c) in the two cases warrants a fine in the amount 

of $500 for each offense, for a total fine of $1,000. 

Count IV

Violation of 11 U.S.C. § 110(h)(2), (3)

98. Plaintiff repeats the allegations contained in Paragraphs 1 through 97 as if set 

forth herein.

99. As a bankruptcy petition preparer Fields is required to accurately disclose the total 

amount of fees received in conjunction with the services performed.

100. Section 110(h)(2) provides that a bankruptcy petition preparer declare under 

penalty of perjury any fee received from the debtor. 

101. Under section 110(h)(3), the bankruptcy petition preparer will forfeit all fees 

charged if full disclosure does not occur. 

102. In the Lucas case, Fields failed to disclose the total amount of fees received in 

connection with the case. 

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103. Fields’ disclosure of $140 is not accurate. Fields attempted to persuade Lucas to 

conceal the true amount paid.

104. Fields’ actions require that the $550 received from Lucas be disgorged and 

returned to him.

105. Fields failed to file the requisite Disclosure of Compensation of Bankruptcy 

Petition Preparer in the Lynch and Blythe case. 

106. Fields did not disclose that Lynch and Blythe paid $150 as a deposit prior to the 

filing of the case with a remaining balance due of $390.

107. Fields’ actions require that the $540 received from Lynch and Blythe be 

disgorged and returned to them.

108. Fields’ violation of §110(b)(2), as noted in Count II, establishes relief under §

110(h)(3)(b) that all fees paid to Fields in the Hall case should be disgorged. 

109. Fields’ violation of §110(b)(2), as noted in Count II, establishes relief under § 

110(h)(3)(b) that all fees paid to Fields in the Aaron case should be disgorged.

110. Fields should be ordered to return the fees received in each of the above listed 

cases as follows: 

Lavene A. 

Hall

15-51352-SCS $140

Teneshia 

Aaron

15-51392-FJS $140

Reginald D. 

Lucas

15-51661-FJS $550

Jeremy 

Lynch and 

Lacresha 

Blythe

15-74476-SCS $540

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Count V

Violation of 11 U.S.C. §110(e)(2)

111. Plaintiff repeats the allegations contained in Paragraphs 1 through 110 as if set 

forth herein.

112. Under section 110(e)(2)(A) a bankruptcy petition preparer is strictly prohibited 

from rendering legal advice. See In re Jay, 446 B.R. 227 (Bankr. E.D.Va. 2010) (St. John, C.J.)

113. In the Hall, Aaron, Lucas and Lynch and Blythe cases, Fields engaged in the 

unauthorized practice of law.

114. Fields prepared a Homestead Deed for Lynch and Blythe. This constitutes the 

practice of law. Jay, 446 B.R. at 246.

115. Fields prepared a Homestead Deed for Lucas. This constitutes the practice of law.

Id. 

116. Fields prepared a Homestead Deed for Hall. This constitutes the practice of law 

Hall. Id.

117. Fields prepared a Homestead Deed for Aaron. This constitutes the practice of law. 

Id.

118. Fields assisted in the preparation and provided advice as to the filing of a Motion 

to Extend Time for Lucas, which constitutes the practice of law in violation of § 110(e)(2).

119. Fields claimed exemptions for Lucas, which constitutes the practice of law in 

violation of § 110(e)(2).

120. Fields advised Lucas not to pay his vehicle and rental payments, which constitutes 

the practice of law in violations of §110(e)(2).

121. Fields advised Lucas to file a bankruptcy petition to stop wage garnishments, 

which constitutes the practice of law in violation of § 110(e)(2).

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122. Fields prepared an application to waive the filing fee in the case of Lucas, which 

constituted an unauthorized practice of law in violation of § 110(e)(2).

123. Fields prepared an application to waive the filing fee in the case of Lynch and 

Blythe, which constituted an unauthorized practice of law in violation of § 110(e)(2).

124. Fields advised Lynch and Blythe not to pay their vehicle payments, which 

constitutes the practice of law in violation of § 110(e)(2).

125. Fields advised Lynch and Blythe about the Homestead Deed and applicable 

monetary limits which constitutes the practice of law in violation of § 110(e)(2).

126. Fields advised Lynch and Blythe about whether to pay rental payments, which 

constitutes the practice of law in violation of § 110(e)(2).

127. Fields advised Aaron about the differences between a Chapter 7 and Chapter 13 

bankruptcy proceeding.

128. Fields advised Aaron about which exemptions to take in filing her Schedule C, 

which constitutes the practice of law in violation of § 110(e)(2).

129. Fields advised Hall about which exemptions to take in the filing of her Schedule 

C, which constitutes the practice of law in violation of § 110(e)(2).

130. Pursuant to 11 U.S.C. § 110(l)(1), Fields is subject to fines of $500 for each 

violation of this section. 

131. In the Hall case, Fields should be fined $500 for the preparation of the Homestead 

Deed and Schedule C, for a total fine of $1,000.

132. In the Aaron case, Fields should be fined $500 for the preparation of the 

Homestead Deed, discussing the differences between Chapter 13 and Chapter 7, and the 

preparation of her Schedule C, for a total fine of $1,500.

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133. In the Lucas case, Fields should be fined $500 for the preparation of the 

Homestead Deed, Schedule C, Application to Waive Filing Fee, Motion to Extend, providing 

advice about paying debts, and advising about the legal effect of filing a bankruptcy petition to 

stop a wage garnishment, for a total fine of $3,000.

134. In the Lynch and Blythe case, Fields should be fined $500 for preparing the 

Homestead Deed for each debtor, discussing whether to make vehicle payments, whether to

make rental payments, and preparing the Application to Waive Filing Fee for a total fine of 

$2,500.

135. As set forth above, Fields should be fined a total of $8,000 for her violations of 11 

U.S.C. § 110(e)(2).

Count VI

Violation of 11 U.S.C. § 110(i)(1)

136. Plaintiff repeats the allegations contained in Paragraphs 1 through 135 as if set 

forth herein.

137. Section 110(i)(1), prohibits bankruptcy petition preparers from committing “any 

fraudulent, unfair, or deceptive act...” 11 U.S.C. § 110(i)(1).

138. Fields’ conduct of engaging in the unauthorized practice of law in the cases of

Hall, Aaron, Lucas and Lynch and Blyth constitutes a fraudulent, unfair or deceptive act within 

the context of § 110(i)(1).

139. Fields’ intentional failure to disclose all fees paid by the debtors, in the cases of 

Lucas and Lynch, and Blythe, under penalty of perjury, constitutes an unfair and deceptive act 

within the meaning of § 110(i)(1).

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140. Fields’ unauthorized practice of law in the Hall, Aaron, Lucas, and Lynch and 

Blythe cases merits statutory damages of $2,000 per case payable to each respective debtor as 

required under § 110(i)(1)(B), for a total of $8,000.

Count VII

11 U.S.C. § 110(l)(2)(D) Treble Damages

141. Plaintiff repeats the allegations contained in Paragraphs 1 through 140 as if set 

forth herein.

141. Counts I – V above request $500 fines for each of Fields’ violations of 11 U.S.C. 

§ 110 (b), (c), (e), and (h).

142. Pursuant to 11 U.S.C. § 110(l)(2)(D), each such fine should be tripled.

143. In each case referred to above, Fields prepared a document for filing in a manner 

that failed to disclose her identity as a bankruptcy petition preparer. 

COUNT VIII

Injunctive Relief under 11 U.S.C. § 110(j)(2)(B)

144. Plaintiff repeats the allegations contained in Paragraphs 1 through 143 as if set

forth herein.

145. Section 110(j) provides a right to bring a civil action for injunctive relief against a 

bankruptcy petition preparer. 11 U.S.C. § 110(j)(1).

146. Pursuant to section 110(j)(2), the bankruptcy court may enjoin a person from ever 

again acting as a bankruptcy petition preparer if it finds that the person has, among other things, 

(i) continually violated section 110 and the Bankruptcy Code or "engaged in any other 

fraudulent, unfair, or deceptive conduct" and merely enjoining the conduct would not be 

sufficient to prevent continued interference with the proper administration of the Bankruptcy 

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Code, (ii) failed to pay a penalty imposed under section 110, or (iii) failed to disgorge fees as 

ordered by the court. 11 U.S.C. § 110(j)(2)(B).

147. Here Fields has engaged in “fraudulent [or] unfair conduct”, 11 U.S.C. §

110(j)(2)(A)(i)(III), which warrants enjoining the bankruptcy petition preparer from engaging in 

such conduct.

148. Fields has engaged in repeated violations of various provisions under § 110 and 

her pattern of past behavior is indicative of possible future reoccurrences, such that a permanent 

injunction from acting as a bankruptcy petition preparer in the United States Bankruptcy Court 

for the Eastern District of Virginia is warranted.

WHEREFORE, United States Trustee respectfully requests that this Court

A. Pursuant to 11 U.S.C. § 110(l)(1), and (3) impose a fine of $12,000 tripled to 

$36,000 per § 110(l)(2)(D), against Fields payable to the United States Trustee for deposit 

pursuant to 11 U.S.C. § 110(l)(4)(A); and

B. Order the immediate forfeiture and turnover by Fields of all fees collected from 

each of the four debtors and that all funds be refunded to the debtors

1

, pursuant to 11 U.S.C. § 

110(h)(3); and

C. Award statutory damages in favor of Hall, Aaron, Lucas and Lynch and Blythe,

and against Fields in the amount of $2,000 per case for a total of $8,000 pursuant to 11 U.S.C. § 

110(i)(1); and

 1 Fields should repay all funds received as follows:

Lavene A. Hall 15-51352-SCS $140

Teneshia 

Aaron

15-51392-FJS $140

Reginald D. 

Lucas

15-51661-FJS $550

Jeremy Lynch 

and Lacresha 

Blythe

15-74476-SCS $540

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D. Pursuant to 11 U.S.C. § 110(j)(2)(B) permanently enjoining Fields from acting as 

a bankruptcy petition preparer in the Eastern District of Virginia; and

E. Grant the United States Trustee such additional relief to which she may be 

entitled.

RESPECTFULLY SUBMITTED, 

Judy A. Robbins 

U.S. Trustee for Region Four 

By: /s/ Nicholas S. Herron

Kenneth N. Whitehurst, III 

Assistant U.S. Trustee 

Nicholas S. Herron

Trial Attorney 

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