IN THE UNITED STATES BANKRUPTCY COURT

FOR THE EASTERN DISTRICT OF VIRGINIA

Richmond Division 

) Case No. 16-34245

FREDRICK L. REID ) Chapter 13

Debtor. ) Suzanne Wade, Ch 13 Trustee

MOTION TO CONTINUE AUTOMATIC STAY

COMES NOW Fredrick L. Reid, by counsel, Nupa Agarwal, pursuant to 11 U.S.C. § 

362(c)(3)(B) , and requests that the Court grant an extension of the automatic stay 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 Chapter 13 proceeding. In support of this Motion the Debtor states as follows:

1. Jurisdiction of this Court over the instant matter is based upon 28 U.S.C.§§1334 and 

157 in that this action arises in and relates to this bankruptcy case of the Debtor, filed in this 

Court on March 16, 2017. 

2. This proceeding is a core proceeding under 28 U.S.C. §157(b)(2)(A), (B),(K), and 

(O).

3. Venue is proper pursuant to 28 U.S.C. §1409.

4. On March 16, 2017, 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”). Suzanne Wade was appointed to serve as Chapter 13 Trustee in this case.

5. The Debtor has filed previous bankruptcy cases: The most recently filed previous case 

was a Chapter 13 filed on August 26, 2016 and dismissed on November 14, 2016.The prior case 

was dismissed because the Debtor failed to provide information for Objection to Confirmation.

The debtor now understands he needs to provide the information the trustee request within a 

timely matter.

6. The instant case was filed on March 16, 2017 which is within one year of the 

dismissal date of the prior bankruptcy thus triggering the provision of 11 U.S.C. 362(c)(3).

7. The Debtor’s prior case was dismissed for not providing all the documents the 

Trustee requested including previous year’s tax returns. The debtor did not realize he only had a 

certain amount of time to get those documents to his attorney. Debtor understands the 

importance of this Chapter 13 and will use all his “financial means” to make this case work. His

current attorney has discussed with him the importance of reading all documents and taking 

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responsibility for his case. He has now filed all tax returns and his attorney has copies of the tax 

transcripts. 

8. The automatic stay will expire on April 16, 2017 which is 30 days after this case was 

filed.

9. The Debtor filed this case in good faith.

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 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) and for such other and further relief as the 

Court shall be deemed appropriate.

Respectfully submitted:

Fredrick L. Reid

By: /s/ Nupa Agarwal

Counsel for Debtor

VA. State Bar No. 42545 

P.O. Box 17275

Richmond, Virginia 23226

PROOF OF SERVICE

I certify that I have this 22nd Day of March 2017 transmitted a true copy of the foregoing 

application electronically through the Court‘s CM/ECF system or by mail to the Debtor, Fredrick L. 

Reid, 300 West 27th Street, Richmond, VA 23225; Chapter 13 Trustee, the United States trustee and to 

all necessary parties, on the mailing matrix maintained by the clerk of court, a copy of which is attached. 

/s/Nupa Agarwal

Nupa Agarwal

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IN THE UNITED STATES BANKRUPTCY COURT

FOR THE EASTERN DISTRICT OF VIRGINIA

Richmond Division 

) Case No. 16-34245

FREDRICK L. REID ) Chapter 13

Debtor. )

NOTICE OF MOTION AND HEARING

The above-named Debtor having filed papers with the court 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.

Pursuant to Local Bankruptcy Rule 6004-4, unless a written response to this motion 

objecting to the relief requested is filed with the Clerk of the Court and served on the moving 

party within fourteen (14) days, the Court may deem any opposition waived, treat the motion 

as conceded, and issue an order granting the requested relief without furthis notice or hearing.

You must also attend a hearing on the Motion to Extend the Automatic Stay, scheduled 

to be held onAPRIL 12, 2017, at 12PM, in Judge Huennekens Courtroom at the U.S. 

Bankruptcy Court, 701 E. Broad Street, Courtroom 5000, Richmond, VA, 23219.

You must also mail a copy of your response to Nupa Agarwal, Esquire, Counsel for 

Debtor, P.O. Box 17275, Richmond, VA 23226.

If you or your attorney does 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 motion.

Date: March 22, 2017

/s/ Nupa Agarwal 

Nupa Agarwal, Esq.

Va. State Bar No. 42545 

P.O. Box 17275

Richmond, Virginia 23226

(804) 716-0493

PROOF OF SERVICE

I certify that I have this 22nd Day of March 2017 transmitted a true copy of the foregoing application electronically 

through the Court‘s CM/ECF system or by mail to the Debtor, Fredrick L. Reid, 300 West 27th Street, Richmond, VA 

23225; Chapter 13 Trustee, the United States trustee and to all necessary parties, on the mailing matrix maintained by 

the clerk of court, a copy of which is attached. 

/s/Nupa Agarwal

Nupa Agarwal

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Department of Treasury-IRS

IRS

PO Box 7346

Philadelphia, PA 19101

Capital One

Po Box 30285

Salt Lake City, UT 84130

Capital One Bank N.A.

Bankruptcy Dept.

PO Box 5155

Norcross, GA 30091

Chesterfield County Gen Dist.

9500 Courthouse Road

P.O. Box 144

Chesterfield, VA 23832

Client Services Inc.

3451 Harry Truman Blvd

Saint Charles, MO 63301

Commonwealth of VA-Tax

PO Box 2156

Richmond, VA 23218

Credit Collection Services

725 Canton Street

Norwood, MA 02062

Credit Collections services

PO Box 55126

Boston, MA 02205-5126

Enhanced Recovery Corp

8014 Bayberry Rd

Jacksonville, FL 32256

First Premier Bank

601 S Minneaplois Ave

Dious FDalls, SD 57104

Firstsource Advantage , LLC

PO Box 628

Buffalo, NY 14240-0628

Internal Revenue Service

Insolvency Unit

Post Office Box 21126

Philadelphia, PA 19114

IRS Centralized Insolvency Ope

PO BOx 7346

Philadelphia, PA 19101-7346

Mariner Finance

8211 Town Center Drive

Suite 106

Nottingham, MD 21236

Merrick Bank

Po Box 660702

Dallas, TX 75266-0702

Nationstar Mortgage LLC

Attn: Bankruptcy

Po Box 619096

Dallas, TX 75261-9741

T-Mobile

PO Box 742596

Cincinnati, OH 45274

Wells Fargo

Attn: Bankruptcy

1 Home Campus X2303-01a

Des Moines, IA 50328

Wells Fargo Bank Nv Na

Po Box 5058

Bankruptcy MAC# P6053-021

Portland, OR 97208-5058

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