Attorney for Debtor

Pia J. North, Esq. #29672

North Law 

5913 Harbour Park Drive

Midlothian, VA 23112

Tel: (804) 739-3700 

Fax: 739-2550 

UNITED STATES BANKRUPTCY COURT

EASTERN DISTRICT OF VIRGINIA

Richmond Division

IN RE: Joeann L. Johnson, Debtor Case#: 16-33221 

10600 Haverford Lane Trustee: Carl M. Bates

North Chesterfield, V A 23236 Chapter: 13 

Last 4 of SSN: xxx-xx-2709 

MOTION TO SHORTEN NOTICE PERIOD

And EXPEDITE HEARING

for Motion to Extend the Automatic Stay

COMES NOW the Debtor, Joeann L. Johnson by counsel and moves this Court pursuant to Local 

Rule 9013-1 (N) to set a hearing on the Debtor’s Motion to Extend the Automatic Stay for a hearing 

as soon as practical and Motion to Shorten the Notice Period in this matter. In support of this Motion 

the Debtor states as follows:

1. Debtor filed a Chapter 13 bankruptcy on June 29, 2016. The Debtor filed a Motion to

Extend the Automatic Stay on July 6, 2016.

2. An emergency exists in that an Order to Extend the Automatic Stay must be entered on

or before July 29, 2016. The only date available within this 30-day period is July 13,

2016. 

WHEREFORE, Debtor requests that the Court shorten the notice period on the Debtor’s 

Motion to Extend the Automatic Stay to not less than two days prior to the hearing to be set by 

the Court in this matter, and for any and all other relief just and proper. 

Joeann L. Johnson 

BY: /s/ Pia J. North 

Counsel 

Case 16-33221-KLP Doc 12 Filed 07/06/16 Entered 07/06/16 17:37:06 Desc Main

 Document Page 1 of 11
Certification

I, Pia J. North certify that I am the attorney for the Debtor and further that I have: 

(1) Carefully examined the matter and concluded that there is a true need for an

emergency hearing,

(2) Not created the emergency through any lack of due diligence, and 

(3) Have made a bona fide effort to resolve the matter without a hearing. (There is no way to resolve 

this issue without an Order from the Court) 

 /s/ Pia J. North 

 Pia J. North, Esquire 

CERTIFICATE OF SERVICE

I certify that a copy of the foregoing Motion to Shorten Notice Period and Motion for an Expedited Hearing, 

Notice of Motion and Notice of Hearing was served by ECF or mailed, by first class mail, this 7th day of July to 

the Debtor, Chapter 13 Trustee and all creditors and other parties of interest herein. 

/s/ Pia J. North 

Pia J. North, Esquire

Case 16-33221-KLP Doc 12 Filed 07/06/16 Entered 07/06/16 17:37:06 Desc Main

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Attorney for Debtor

Pia J. North, Esq. #29672

North Law 

5913 Harbour Park Drive

Midlothian, VA 23112

Tel: (804) 739-3700 

Fax: 739-2550 

UNITED STATES BANKRUPTCY COURT

EASTERN DISTRICT OF VIRGINIA

Richmond Division

IN RE: Joeann L. Johnson, Debtor Case#: 16-33221 

10600 Haverford Lane Trustee: Carl M. Bates

North Chesterfield, V A 23236 Chapter: 13 

Last 4 of SSN: xxx-xx-2709 

NOTICE OF MOTION TO SHORTEN NOTICE PERIOD

And EXPEDITE HEARING 

Counsel for Joeann L. Johnson, Debtor has filed papers with the court to Shorten the Notice Period on 

the Debtor’s Motion to Extend the Automatic Stay.

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 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 you or your attorney must file with the court, at the address 

shown below, a written request for a hearing or a written response pursuant to Local Bankruptcy Rule 9013-1 (H). 

If you mail your request for hearing or response to the court for filing, you must mail it early enough so the court 

will receive it at least two (2) days prior to the hearing on the Motion to Shorten Notice Period and Expedite 

hearing that will be set by the Court in this matter, at the United States Bankruptcy Court, 701 E. Broad Street,

Suite 4000, Richmond, Virginia, Richmond, VA 23219. 

You must also mail a copy to: 

Pia J. North

North Law

5913 Harbour Park Drive

Midlothian, VA 23112

Chapter 13 Trustee

Carl M. Bates

P.O. Box 1819

Richmond, VA 23219

NOTICE IS HEREBY GIVEN PURSUANT TO LOCAL RULE 9013-1, UNLESS A WRITTEN 

RESPONSE TO THIS MOTION AND SUPPORTING MEMORANDUM ARE FILED WITH THE 

CLERK OF COURT AND SERVED ON THE MOVING PARTY NOT LESS THAN 2 (TWO) DAYS 

PRIOR TO THE HEARING ON THE MOTION TO EXTEND THE AUTOMATIC STAY, THE 

COURT MAY DEEM ANY OPPOSITION WAIVED AND ISSUE AN ORDER SUSTAINING THE 

MOTION WITHOUT FURTHER NOTICE OR 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 that relief. 

Joeann L. Johnson 

BY: /s/ Pia J. North 

Counsel 

Case 16-33221-KLP Doc 12 Filed 07/06/16 Entered 07/06/16 17:37:06 Desc Main

 Document Page 3 of 11
Attorney for Debtor

Pia J. North, Esq. #29672

North Law 

5913 Harbour Park Drive

Midlothian, VA 23112

Tel: (804) 739-3700 

Fax: 739-2550 

UNITED STATES BANKRUPTCY COURT

EASTERN DISTRICT OF VIRGINIA

Richmond Division

IN RE: Joeann L. Johnson, Debtor Case#: 16-33221 

10600 Haverford Lane Trustee: Carl M. Bates

North Chesterfield, V A 23236 Chapter: 13 

Last 4 of SSN: xxx-xx-2709 

NOTICE of HEARING

 PLEASE TAKE NOTICE that on July 13, 2016 @ 10:00 A.M. or as soon thereafter as is practical, we 

will appear before the Honorable Keith L. Phillips in Courtroom 5100 of the United States Bankruptcy 

Court, Eastern District of Virginia, Richmond Division located at 701 E. Broad Street, Richmond, 

Virginia on the Debtor’s Motion to Extend the Automatic Stay. 

 Joeann L. Johnson 

BY: /s/ Pia J. North 

Counsel 

Case 16-33221-KLP Doc 12 Filed 07/06/16 Entered 07/06/16 17:37:06 Desc Main

 Document Page 4 of 11
Attorney for Debtor

Pia J. North, Esq. #29672

North Law 

5913 Harbour Park Drive

Midlothian, VA 23112

Tel: (804) 739-3700 

Fax: 739-2550 

UNITED STATES BANKRUPTCY COURT

EASTERN DISTRICT OF VIRGINIA

Richmond Division

IN RE: Joeann L. Johnson, Debtor Case#: 16-33221 

10600 Haverford Lane Trustee: Carl M. Bates

North Chesterfield, V A 23236 Chapter: 13 

Last 4 of SSN: xxx-xx-2709 

MOTION TO EXTEND AUTOMATIC STAY

Comes Now, the Debtor, Joeann L. Johnson, by Counsel, Pia J. North, Esq. and states the 

following in support of this Motion: 

1. On, June 29, 2016, the Debtor filed in this Honorable Court a petition for relief under Chapter 13 of

the Bankruptcy Code, 11 U.S.C. § 1301 et seq. (the “instant case”). Carl M. Bates was appointed to

serve as Chapter 13 trustee in this case (the “Trustee”).

2. The Debtor, Joeann L. Johnson, had one previous bankruptcy pending within a year. Case# 13-31243

filed on March 8, 2013 and dismissed on May 16, 2016 for default in plan payments under the Chapter

13 plan. The dismissal of the prior case hastriggered the provision of 11 U.S.C. 362(c)(3). The Debtor

also received a discharge in a Chapter 13 case filed more than 12 years ago. Case #04-33415, was filed

April 7, 2004 and discharged on or about May 29, 2009. The Debtor’s bankruptcy history does not

indicate a lack of good faith.

3. The automatic stay will expire in the instant case on July 29, 2016, unless the Court extends the

automatic stay pursuant to 11 U.S.C362 (c)(3)(A) and (B).

4. The Debtor lost her job during the prior case, fell behind in her payments and was unable to catch up.

There has been a positive change in the Debtor’s circumstances. In the instant case, the Debtor has

several sources of income to draw on. She receives employment income from Care Family and also

works as a self-employed private duty nurse. In addition to that income, she receives Social Security

income for her grandson. Recently, the Debtor’s adult daughter has agreed to share expenses by

making a regular monthly contribution to the household.

Case 16-33221-KLP Doc 12 Filed 07/06/16 Entered 07/06/16 17:37:06 Desc Main

 Document Page 5 of 11
5. The Debtor has filed this case in good faith and has proposed a confirmable plan paying a 100%

dividend to her unsecured creditors.

WHEREFORE, for the foregoing reasons, the Debtor respectfully requests that this Court enter an 

Order extending the automatic stay under 11 U.S.C. § 362 as to all creditors, as to the Debtor and the 

Debtor’s property, and as to the property of the estate for the duration of this matter 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) and for such other and further relief as to the Court shall be deemed appropriate. 

Respectfully submitted:

Joeann L. Johnson

By: /s/ Pia J. North

Counsel 

Case 16-33221-KLP Doc 12 Filed 07/06/16 Entered 07/06/16 17:37:06 Desc Main

 Document Page 6 of 11
Attorney for Debtor

Pia J. North, Esq. #29672

North Law 

5913 Harbour Park Drive

Midlothian, VA 23112

Tel: (804) 739-3700 

Fax: 739-2550 

UNITED STATES BANKRUPTCY COURT

EASTERN DISTRICT OF VIRGINIA

Richmond Division

IN RE: Joeann L. Johnson, Debtor Case#: 16-33221 

10600 Haverford Lane Trustee: Carl M. Bates

North Chesterfield, V A 23236 Chapter: 13 

Last 4 of SSN: xxx-xx-2709 

NOTICE OF MOTION

Pia J. North, Attorney for the Debtor having filed papers with the court: Motion to Extend the 

Automatic Stay. 

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 objection, or if you want the court to 

consider your views on the motion, then on or before two days prior to the hearing on July 13, 2016

you or your attorney must: File with the court, at the address shown below, a written response pursuant to 

Local Bankruptcy Rule 9013-1(H)]. If you mail your request for hearing (or response) to the court for 

filing, you must mail it early enough so the court will receive it on or before the date stated above. 

Clerk of Court 

United States Bankruptcy Court 

701 E. Broad Street, Room 4000 

Richmond, VA 23219 

Office of the U.S. Trustee 

701 E. Broad Street, Room 4304 

Richmond, Virginia 23219 

You must also mail a copy to: 

Pia J. North 

North Law 

5913 Harbour Park Drive 

Midlothian, VA 23112 

Carl M. Bates

P.O. Box 1819 

Richmond, VA 23218-1819 

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 that relief. 

 Joeann L. Johnson 

 By: /s/ Pia J. North 

 Counsel 

Case 16-33221-KLP Doc 12 Filed 07/06/16 Entered 07/06/16 17:37:06 Desc Main

 Document Page 7 of 11
Attorney for [1]

Pia J. North, Esq. #$29672

North Law

5913 Harbour Park Drive

Midlothian, VA 23112

(804) 739-3700 

United States Bankruptcy Court

Eastern District of Virginia

Richmond Division

IN RE: Joeann L. Johnson, Debtor Case#: 16-33221 

10600 Haverford Lane Trustee: Carl M. Bates

North Chesterfield, V A 23236 Chapter: 13 

Last 4 of SSN: xxx-xx-2709 

NOTICE

PLEASE TAKE NOTICE that on July 13, 2016 or as soon thereafter as is practical, we will

appear before the Honorable Keith L. Phillips United States Bankruptcy Court, Eastern District of 

Virginia, Richmond Division, 701 E. Broad Street, Room 5100, Richmond, VA 23219,

Richmond, VA 23219 on the Debtor’s Motion to Extend the Automatic Stay.

Joeann L. Johnson 

BY: /s/ Pia J. North 

Counsel 

Certificate of Service

I hereby certify that I have on July 6, 2016, I served by transmitting a true copy of the foregoing Motion to 

Extend the Automatic Stay, Notice of Motion and Notice of Hearing electronically through the Court’s 

CM/ECF system or by first class mail, postage pre-paid to: Joeann L. Johnson, the Debtor, the Trustee, the 

United States trustee and to all creditors and parties in interest on the attached mailing matrix 

By: /s/ Pia J. North

 Counsel

Case 16-33221-KLP Doc 12 Filed 07/06/16 Entered 07/06/16 17:37:06 Desc Main

 Document Page 8 of 11
Attorney for Debtor

Pia J. North, Esq. #29672

North Law 

5913 Harbour Park Drive

Midlothian, VA 23112

Tel: (804) 739-3700 

Fax: 739-2550 

United States Bankruptcy Court

Eastern District of Virginia

Richmond Division

IN RE: Joeann L. Johnson, Debtor 

10600 Haverford Lane 

North Chesterfield, V A 23236 

Case#: 16-33221 

Trustee: Carl M. Bates 

Chapter: 13 

Last 4 of SSN: xxx-xx-2709 

AFFIDAVIT 

I, Joeann L. Johnson declare under penalty of perjury that the information provided in the Motion to 

Extend the Automatic Stay is true and correct. 

1. I was previously in a Chapter 13 bankruptcy filed March 2013 and dismissed in May 2016. That

case was dismissed because I lost my job and was unable to make the chapter 13 plan payments

each month.

2. Since the prior bankruptcy my financial situation has improved. I am employed with a private duty

nursing agency.

3. My income is stable and I now have several sources of income which include employment at Care

Family, income from private duty nursing, grandson’s social security and rental income from my

daughter.

4. I am paying my creditors 100%.

5. I believe that I can make regular monthly payments on my chapter 13 plan.

Date: June 29, 2016 /s/ Joeann L. Johnson 

Joeann L. Johnson 

Case 16-33221-KLP Doc 12 Filed 07/06/16 Entered 07/06/16 17:37:06 Desc Main

 Document Page 9 of 11
 Label Matrix for local noticing United States Bankruptcy Court Afni

 0422-3 701 East Broad Street 1310 Martin Luther King Dr

 Case 16-33221-KLP Richmond, VA 23219-1888 Bloomington, IL 61701-1465

 Eastern District of Virginia

 Richmond

 Wed Jul 6 17:24:01 EDT 2016

 Branch Bank & Trust CJW Center Commonwealth of VA-Tax

 P O Box 2027 P.O. Box 740760 P.O. Box 2156

 Greenville, SC 29602-2027 Cincinnati, OH 45274-0760 Richmond, VA 23218-2156

 Convergent Outsource (p)DIRECTV LLC Dept Of Ed/Nelnet

 800 Sw 39th Street ATTN BANKRUPTCIES 3015 Parker Rd

 Renton, WA 98057-4975 PO BOX 6550 Aurora, CO 80014-2904

GREENWOOD VILLAGE CO 80155-6550

 Dept Of Ed/Nelnet Diversified Consultant (p)FOCUSED RECOVERY SOLUTIONS

 Attn: Claims Dci 9701 METROPOLITAN COURT

 Po Box 82505 Po Box 551268 STE B

 Lincoln, NE 68501-2505 Jacksonville, FL 32255-1268 RICHMOND VA 23236-3690

 Glasser & Glasser, P.L.C. Interior Air Internal Revenue Service

 Collections Dept. P.O, Box 746 Centralized Insolvency Unit

 PO Box 3400 Mechanicsville, VA 23111-0746 P O Box 7346

 Norfolk, VA 23514-3400 Philadelphia, PA 19101-7346

 Kohls/Capone New Generations Fede Nicholas Finance Corp.

 Po Box 3115 1700 Robin Hood Road 2454 Mcmullen Booth Road

 Milwaukee, WI 53201-3115 Richmond, VA 23220-1012 Clearwater, FL 33759-1343

 (p)PORTFOLIO RECOVERY ASSOCIATES LLC Receivable Management Inc Receivable Management Inc

 PO BOX 41067 7206 Hull Rd Pob 17305

 NORFOLK VA 23541-1067 Ste 211 Richmond, VA 23226-7305

Richmond, VA 23235

 Regional Acc (p)SPRINT NEXTEL CORRESPONDENCE St Francis Medical Center

 5425 Robin Road ATTN BANKRUPTCY DEPT P.O. Box 404893

 Norfolk, VA 23513-2441 PO BOX 7949 Atlanta, GA 30384-4893

OVERLAND PARK KS 66207-0949

 St Loan Fund (p)C O AMERICAN INFOSOURCE LP Verizon

 C/o Acs 4515 N SANTA FE AVE 500 Technology Dr

 U, NY 13501 OKLAHOMA CITY OK 73118-7901 Suite 500

Weldon Spring, MO 63304-2225

 Verizon Verizon Carl M. Bates

 500 Technology Dr National Recovery P. O. Box 1819

 Weldon Spring, MO 63304-2225 Minneapolis, MN 55426 Richmond, VA 23218-1819

Case 16-33221-KLP Doc 12 Filed 07/06/16 Entered 07/06/16 17:37:06 Desc Main

 Document Page 10 of 11
 Joeann L. Johnson Pia J. North 

 10600 Haverford Lane North Law 

 North Chesterfield, VA 23236-2978 5913 Harbour Park Drive 

 Midlothian, VA 23112-2163 

 

 The preferred mailing address (p) above has been substituted for the following entity/entities as so specified 

 by said entity/entities in a Notice of Address filed pursuant to 11 U.S.C. 342(f) and Fed.R.Bank.P. 2002 (g)(4). 

 DIRECTV Focus Recry Portfolio Recovery Associates 

 P.O. Box 11732 9701 Metropolitan Suite B PO Box 41067 

 Newark, NJ 07101 Richmond, VA 23236 Norfolk, VA 23541 

 Sprint Tmobile USA 

 Attention: Bankruptcy PO Box 742596 

 PO Box 7949 Cincinnati, OH 45274 

 Overland Park, KS 66207 

 The following recipients may be/have been bypassed for notice due to an undeliverable (u) or duplicate (d) address. 

 (u)Johnston Willis Hospital End of Label Matrix 

 Mailable recipients 31 

 Bypassed recipients 1 

 Total 32

Case 16-33221-KLP Doc 12 Filed 07/06/16 Entered 07/06/16 17:37:06 Desc Main

 Document Page 11 of 11