IN THE UNITED STATES BANKRUPTCY COURT

FOR THE EASTERN DISTRICT OF VIRGINIA

Alexandria Division

In re: * 

 * Case No. 16-10881-RGM

GARY L. JACOBS * 

 * Chapter 13

Debtor * 

MOTION TO EXTEND AUTOMATIC STAY

COMES NOW Gary L. Jacobs, the Debtor, through undersigned counsel, and 

respectfully move this Court, pursuant to 11 U.S.C. § 362(c)(3)(B), for an order continuing the 

automatic stay as to the Debtor as provided under § 362(a). This request is being made as to all 

creditors in this case. In support of this motion, the Debtor states as follows:

1. This case was commenced by the filing of a voluntary petition under Chapter 13 

of the Bankruptcy Code with the Clerk of this Court on March 11, 2016. 

2. The Debtors had previously filed a Chapter 13 case that was dismissed on 

September 15, 2015. 

3. This case was dismissed because an amended plan was not filed within 21 days of 

the Order denying Confirmation entered on August 24, 2015

4. Debtor alleges that this was because his previous attorney refused to perform any 

further work due to a fee dispute.

5. The petition in this case has been filed in good faith. The debtors believe that the 

Chapter 13 plan they have submitted will be confirmed and that they will be able to fully 

perform under the terms of the plan.

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6. The Debtor’s prior Chapter 13 case dismissed on September 15, 2015 was his 

only previous case that was pending during the preceding year. 

WHEREFORE, the Debtor prays:

A. That this Court continue, as to the Debtor, the automatic stay under § 362(a) as to 

all creditors for the duration of this Chapter 13 proceeding, or until such time as the stay is 

terminated under § 362(c)(1) or (c)(2), or a motion for relief is granted under § 362(d); 

B. That the stay in any event be deemed continued as to “all property of this estate” 

in bankruptcy; 

C. That the Debtor has such other and further relief as to the Court may be just an 

proper; and

Respectfully submitted this 22

nd day of March, 2016. 

/s/ Jeremy C. Huang

Jeremy C. Huang, VSB 76861

WOEHRLE DAHLBERG JONES YAO, PLLC

10615 Judicial Dr., Suite 102

Fairfax, VA 22030

703-755-0214 / 571-285-0065

jhuang@lawfirmvirginia.com

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CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on this 22

nd day of March, 2016, a copy of the foregoing 

Motion and Notice of Hearing were served via first class mail, postage prepaid, or the Court’s 

ECF system, upon the Chapter 13 Trustee, U.S. Trustee, and the following parties:

American Financial Res Inc.

PO Box 5914

Santa Rosa, CA 95402-0000

Comcast

8029 Corporate Dr

Nottingham, MD 21236-4977

Commonwealth of Virginia

Dept of Taxation

Po Box 1115

Richmond, VA 23218-1115

Credit Collection Services

Two Wells Ave

Newton Center, MA 02459-0000

Credit One Bank

PO Box 98875

Las Vegas, NV 89193-0000

Dominion Virginia Power

PO Box 26666

Richmond, VA 23261-6666

Harley Davidson Credit Corp

PO Box 9013

Addison, TX 75001-0000

Internal Revenue Service

400 N. 8th Street, Box 75

Stop Room 898

Richmond, VA 23219-0000

IPFS Corporation

PO Box 412086

Kansas City, MO 64141-2086

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JLB Associates, Inc.

c/o Robert B. Goodall

1259 Courthouse Rd., Suite 101

Stafford, VA 22554-0000

Kubota Credit Corp

1025 Northbrook Parkway

Suwanee, GA 30024-0000

Lisa A. Vellejos

6 Bryant Blvd

Stafford, VA 22556-0000

Matco Tools

Attn: Carrie

4403 Allen Rd

Stow, OH 44224-0000

Sheffield Financial

PO Box 1704

Clemmons, NC 27012-0000

Snap On Credit

Attn: Bankruptcy

950 Technology Way, Suite 301

Libertyville, IL 60048-0000

/s/ Jeremy C. Huang

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