Robert B. Van Arsdale, AUST (Va. Bar No. 17483) 

Shannon Pecoraro, Esq. (Va. Bar No. 46864) 

Office of the United States Trustee 

701 East Broad Street - Suite 4304 

Richmond, VA 23219 

Telephone (804) 771-2310 

Facsimile (804) 771-2330 

 UNITED STATES BANKRUPTCY COURT 

EASTERN DISTRICT OF VIRGINIA 

RICHMOND DIVISION 

In re 

Harjit Kaur 

1318 Bluewater Drive 

Chester, VA 23836 

SSN/ITIN: xxx-xx-9994, 

 Debtor(s). 

 Case No. 16-31442-KRH 

Chapter 7 

NOTICE OF MOTION TO EXTEND TIME 

(1) TO OBJECT TO DISCHARGE AND (2) TO FILE A 

MOTION TO DISMISS PURSUANT TO 11 U.S.C. § 707 

PLEASE TAKE NOTICE THAT the United States Trustee has filed with the Court a 

Motion To Extend Time (1) To Object To Discharge And (2) To File A Motion To Dismiss 

Pursuant To 11 U.S.C. § 707 (the “Motion”) in the above-captioned case. 

Your rights may be affected. You should read these papers carefully and discuss 

them with your attorney, if you have one in this bankruptcy case. (If you do not have an 

attorney, you may wish to consult one.) 

If you do not want the Court to grant the relief sought in the Motion or if you want the 

Court to consider your views on the Motion, then on or before July 14, 2016, you or your 

attorney must: 

( X ) File with the Court, at the address below, a written request for a hearing 

[or a written response pursuant to Local Bankruptcy Rule 9013-1(H)]. You must 

mail or otherwise file it early enough so the Court will receive it on or before the 

date stated above. 

Clerk of Court 

United States Bankruptcy Court 

701 East Broad Street – Suite 4000 

Richmond, Virginia 23219 

You must also mail a copy to: 

Shannon Pecoraro, Trial Attorney 

Office of the United States Trustee 

 701 East Broad Street - Suite 4304 

 Richmond, VA 23219

Case 16-31442-KRH Doc 24 Filed 06/30/16 Entered 06/30/16 12:13:40 Desc Main

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( x ) Attend a hearing, which may be scheduled at a later date. You will receive a 

separate notice of hearing. 

If you or your attorney do not take these steps, the Court may decide that you do not 

oppose the relief sought in the Motion and may enter an Order granting the relief requested. 

 JUDY A. ROBBINS 

 United States Trustee 

 Region Four 

 /s/ Shannon Pecoraro 

Shannon Pecoraro, Trial Attorney 

Office of the United States Trustee 

701 East Broad Street - Suite 4304 

Richmond, VA 23219 

Telephone (804) 771-2310 

Facsimile (804) 771-2330 

 

CERTIFICATE OF SERVICE

I hereby certify that on June 30, 2016, a true copy of the foregoing was served via 

electronic mail pursuant to the Administrative Procedures of the CM/ECF System for the United 

States Bankruptcy Court for the Eastern District of Virginia to all necessary parties. In addition, 

a copy was mailed to the following: 

Harjit Kaur 

1318 Bluewater Drive 

Chester, VA 23836 

 /s/ Shannon Pecoraro 

Shannon Pecoraro, Esq. 

Trial Attorney 

Date: June 30, 2016 

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Robert B. Van Arsdale, Esq., AUST (Va. Bar No. 17483) 

Shannon Pecoraro, Esq. (Va. Bar No. 46864) 

Office of the United States Trustee 

701 East Broad Street - Suite 4304 

Richmond, VA 23219 

Telephone (804) 771-2310 

Facsimile (804) 771-2330 

UNITED STATES BANKRUPTCY COURT 

EASTERN DISTRICT OF VIRGINIA

RICHMOND DIVISION

In re 

Harjit Kaur, 

 Debtor(s). 

 Case No. 16-31442-KRH 

Chapter 7 

 MOTION TO EXTEND TIME TO (1) OBJECT TO DISCHARGE 

AND (2) TO FILE A MOTION TO DISMISS PURSUANT TO 11 U.S.C. § 707 

COMES NOW JUDY A. ROBBINS, the United States Trustee for the Eastern District of 

Virginia (the "U.S. Trustee"), through the undersigned counsel and pursuant to §§ 707 and 727 

of 11 U.S.C. §§ 101, et seq. (the “Bankruptcy Code”) and Bankruptcy Rules 1017(e)(1), 4004, 

4007 and 9006(b) of the Federal Rules of Bankruptcy Procedure, hereby requests this Court to 

extend the time to object to the above-captioned Debtor’s (the “Debtor”) discharge and to extend 

time to file a motion to dismiss this case. In support of this request, the U.S. Trustee states as 

follows: 

1. This is a core proceeding concerning the administration of this estate pursuant to 

28 U.S.C. §157(b)(2)(A) and 28 U.S.C. § 1334. 

2. On or about March 23, 2016, the Debtor filed a voluntary petition for relief under 

Chapter 7 of the Bankruptcy Code. 

3. Peter J. Barrett (the “Chapter 7 Trustee”) was appointed trustee and continues to 

serve as trustee in this bankruptcy case. 

4. The Chapter 7 Trustee and the U.S. Trustee have requested documents from the 

Debtor. The U.S. Trustee recently received documents from the Chapter 7 Trustee and is in the 

process of reviewing same. 

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5. The adjourned § 341 hearing is scheduled for July 25, 2016, which is after the 

expiration of the current deadlines under §§ 707(b) and 727. 

6. Based upon the above, the U.S. Trustee requests an extension of time to file a 

motion to dismiss this case pursuant to Bankruptcy Code § 707 and/or to object to the Debtor’s 

discharge pursuant to Bankruptcy Code § 727. 

7. In the Schedules of Assets and Liabilities (the “Schedules”), the Debtor lists total 

unsecured debt of $471, 645.00. 

8. On Schedule I, the Debtor lists total gross monthly income of $1,500.00 and 

Combined Average Monthly Income of $1,255.00. 

9. The circumstances set forth above constitute sufficient cause for granting the 

requested extension of time. 

10. There have not been any extensions of time filed in this case and the deadline 

expires July 1, 2016. 

WHEREFORE, the U.S. Trustee requests this Court to extend the date to file a motion 

to dismiss pursuant to Bankruptcy Code § 707 and/or to object to the Debtor’s discharge 

pursuant to Bankruptcy Code § 727 through and including, December 1, 2016, and for such other 

relief as this Court deems just. 

Respectfully requested 

JUDY A. ROBBINS 

United States Trustee 

Region Four 

 By: /s/ Shannon Pecoraro 

 Shannon Pecoraro 

 Trial Attorney 

CERTIFICATE OF SERVICE

Date: June 30, 2016 

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I do hereby certify that on June 30, 2016, a true copy of the foregoing was served via 

electronic mail pursuant to the Administrative Procedures of the CM/ECF System for the United 

States Bankruptcy Court for the Eastern District of Virginia to all necessary parties. In addition, 

a copy was mailed to the following: 

 Harjit Kaur 

1318 Bluewater Drive 

Chester, VA 23836 

/s/ Shannon Pecoraro 

Shannon Pecoraro, Esq. 

Trial Attorney 

Office of the United States Trustee 

701 East Broad Street - Suite 4304 

Richmond, VA 23219 

Telephone (804) 771-2310 

Facsimile (804) 771-2330 

Case 16-31442-KRH Doc 24 Filed 06/30/16 Entered 06/30/16 12:13:40 Desc Main

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Robert B. Van Arsdale, Esq., AUST (Va. Bar No. 17483) 

Shannon Pecoraro, Esq. (Va. Bar No. 46864) 

Office of the United States Trustee 

701 East Broad Street - Suite 4304 

Richmond, VA 23219 

Telephone (804) 771-2310 

Facsimile (804) 771-2330 

UNITED STATES BANKRUPTCY COURT 

EASTERN DISTRICT OF VIRGINIA

RICHMOND DIVISION

In re 

Harjit Kaur, 

 Debtor(s). 

 Case No. 16-31442-KRH 

Chapter 7 

ORDER EXTENDING TIME (1) TO FILE A COMPLAINT 

TO OBJECT TO THE DISCHARGE AND (2) TO FILE A 

MOTION TO DISMISS PURSUANT TO 11 U.S.C. § 707 

This matter came before the Court upon the United States Trustee’s Motion To Extend 

Time (1) To Object To Discharge And (2) To File A Motion To Dismiss Pursuant To 11 U.S.C. 

§707 (the “Motion”), and it appearing that due notice was given and that good cause exists to 

grant the relief sought in the Motion, it is hereby ORDERED: 

1. The Motion is GRANTED. 

2. Capitalized terms not otherwise defined herein shall have the meanings given to 

them in the Motion. 

3. The last day to file a complaint to object to the above captioned Debtor’s 

discharge or to file a motion to dismiss this case is extended through and including December 1, 

2016. 

4. Upon entry, the Clerk is directed to send a copy of this Order to all parties on the 

service list attached hereto. 

 

DATE KEVIN R. HUENNEKENS 

BANKRUPTCY JUDGE 

UNITED STATES BANKRUPTCY COURT 

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I ask for this: 

 /s/ Shannon Pecoraro 

Shannon Pecoraro, Esq. 

Office of the United States Trustee 

701 East Broad Street - Suite 4304 

Richmond, VA 23219 

CERTIFICATION

I hereby certify that this Order has been either served on or endorsed by all necessary 

parties. 

 /s/ Shannon Pecoraro 

Shannon Pecoraro, Esq. 

Case 16-31442-KRH Doc 24 Filed 06/30/16 Entered 06/30/16 12:13:40 Desc Main

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SERVICE LIST 

Harjit Kaur 

1318 Bluewater Drive 

Chester, VA 23836 

Peter J. Barrett, Chapter 7 Trustee 

Kutak Rock LLP 

1111 E. Main Street, Suite 800 

Richmond, VA 23219 

Rudolph C. McCollum, Jr., Esq. 

P.O. Box 4595 

Richmond, VA 23220 

Shannon Pecoraro, Esq. 

Trial Attorney 

Office of the United States Trustee 

701 East Broad Street - Suite 4304 

Richmond, VA 23219 

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