Office of the United States Trustee 

115 South Union Street 

Alexandria, Virginia 22314 

(703) 557-7229 

United States Bankruptcy Court 

Eastern District of Virginia 

Alexandria Division 

In re: 

Terence Michael Hynes, 

Kathryn Wilson Hynes, 

 Debtor. 

Case No. 16-10556-BFK 

 Chapter 11 

 Hearing May 3, 2016, at 11:00 am 

 Courtroom III, 3rd Floor 

Notice of Motion and Notice of Hearing 

 The United States Trustee has filed papers with the Court to have the Court set a date 

certain for the filing of a disclosure statement and plan of reorganization by the Debtors, and for 

the Debtors to submit and the Court approve a budget for the Debtors’ expenses. 

 A hearing on the motion will be held: 

Place: 

Martin V.B. Bostetter, Jr. United States Courthouse 

United States Bankruptcy Court 

Courtroom No. III, Third Floor 

200 South Washington Street 

Alexandria, Virginia 22314 

Date and Time: 

Tuesday, May 3, 2016 at 11:00 am 

 

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 wish 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 five days before the scheduled 

hearing date, you or your attorney must: 

■ File with the Court a written response with supporting memorandum as required 

by Local Bankruptcy Rule 9013-1(H). Unless a written response and 

supporting memorandum are filed and served by the date specified, the 

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Court may deem any opposition waived, treat the motion as conceded, and 

issue an order granting the requested relief without further notice or 

hearing. If you mail your 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. You must 

also mail a copy to the persons listed below. 

■ Attend the hearing. 

 If no timely response has been filed opposing the relief requested, the Court 

may grant the relief without holding a hearing. 

■ A copy of any written response must be mailed to the following persons:

United States Trustee 

 115 South Union St, Suite 210 

 Alexandria, VA 22314 

 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 enter an order granting that relief. 

Judy A. Robbins, 

United States Trustee, 

 /s/ Jack Frankel 

 Jack Frankel, Attorney 

 Office of United States Trustee 

 115 S Union Street 

 Alexandria, VA 22314 

 (703) 557-7229 

Certificate of Service 

I hereby certify that on the 4th day of April, 2016, I mailed, United States mail, postage 

prepaid, first class, a copy of this motion and notice of motion and hearing to: 

Brian Andrew Tucci, Esq. 

Goren &Tucci, LLC 

7979 Old Georgetown Road, Suite 750 

Bethesda, MD 20814 

Terence Michael Hynes 

Kathryn Wilson Hynes

7004 Green Oak Drive 

Mc Lean, VA 22101-1551 

 /s/ Jack Frankel 

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