Attorney for Debtor

Christopher M. Winslow, Esquire

Winslow & McCurry, PLLC

1324 Sycamore Square, 202

Midlothian, VA 23113

(804) 423-1382

UNITED STATES BANKRUPTCY COURT

EASTERN DISTRICT OF VIRGINIA

Richmond Division

IN RE: Jiles R. Smith., 

Debtor(s) Case No. : 17-30804-KRH

Chapter 13

NOTICE OF MOTION TO SHORTEN NOTICE PERIOD 

and EXPEDITE HEARING

Christopher M. Winslow, Attorney for the Debtor having filed papers with the court to 

Shorten the Notice Period and Expedite Hearing on the Debtor’s Motion to Vacate Dismissal.

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.)

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 days prior to the hearing on the Motion to Vacate Dismissal that will be set by the Court in this 

matter 

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:

Christopher M. Winslow, Esquire

1324 Sycamore Square, 202

Midlothian, VA 23113

Carl M. Bates

P.O. Box 1819

Richmond, VA 23218-1780

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 (TWO) 2 

DAYS PRIOR TO THE HEARING SCHEDULED FOR DECEMBER 6, 2017 @ 12:00 PM. ON 

THE MOTION TO VACATE DISMISSAL, 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.

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/s/Christopher M. Winslow

Christopher M. Winslow

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Attorney for Debtor

Christopher M. Winslow, Esquire

Winslow & McCurry, PLLC

1324 Sycamore Square, 202

Midlothian, VA 23113

(804) 423-1382

UNITED STATES BANKRUPTCY COURT

EASTERN DISTRICT OF VIRGINIA

Richmond Division

IN RE: Jiles R. Smith., 

Debtor(s) Case No. : 17-30804-KRH

Chapter 13

NOTICE OF HEARING

PLEASE TAKE NOTICE that on December 6, 2017 @ 12:00PM or as soon thereafter as is practical, we 

will appear before the Honorable Kevin R. Huennekens in Room 5000 of the United States Bankruptcy 

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

Virginia on the Debtor’s Motion to Incur Debt.

 

 Jiles R. Smith.

BY: /s/ Christopher M. Winslow

Counsel

 CERTIFICATE

I hereby certify that on November 29, 2017, I mailed the foregoing document by electronic means or first 

class mail, postage pre-paid to:, U.S. Trustee, 701 E. Broad Street, Suite 4300, Richmond, VA 23219, 

the debtor(s), the Chapter 13 Trustee and all creditors and parties of interest herein.

 /s/ Christopher M. Winslow 

Christopher M. Winslow

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UNITED STATES BANKRUPTCY COURT

EASTERN DISTRICT OF VIRGINIA

Richmond Division

In re: 

 

Jiles R. Smith Case No. 17-30804-KRH

 

 Debtor(s) Chapter 13

13524 Ridgemore Dr.

Midlothian, VA 23114 

 

Last four digits of Social Security or Individual Tax-payer 

Identification (ITIN) No(s)., (if any): 5164

MOTION TO SHORTEN NOTICE PERIOD

and EXPEDITE HEARING

COMES NOW the debtor, Jiles R. Smith, by counsel and moves this Court pursuant to Local Rule 

9013-1 (N) to set a hearing on the Debtor’s Motion to Vacate Dismissal for a hearing as soon as practical and 

to Shorten the Notice period in this matter. In support of this Motion the debtor states as follows:

1. Debtor has filed a Motion to Vacate Dismissal.

2. Debtor’s case was dismissed on November 28, 2017 by Order of Dismissal Upon Denial of 

Confirmation.

3. An emergency exists in that the Debtor has unsecured priority arrears with DCSE which are 

supposed to be paid through the Chapter 13 plan. It is imperative that the dismissal is vacated and 

the plan be confirmed as soon as possible to avoid State Court action. 

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

Vacate Dismissal and to set an Expedite hearing in this matter as soon as practical and for any and all 

other relief just and proper. 

Respectfully Submitted:

Jiles R. Smith.

By: /s/ Christopher M. Winslow

Attorney for Debtor

Christopher M. Winslow, Esquire

Winslow & McCurry, PLLC

1324 Sycamore Square, 202

Midlothian, VA 23113

(804) 423-1382

Certification

I Christopher M. Winslow 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

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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 hearing. (There is no way to resolve 

this issue without an Order from the Court)

/s/ Christopher M. Winslow

CERTIFICATE OF SERVICE

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

hearing and the Notice of Motion was mailed by electronic means or by first class mail, this 

November 29, 2017 to the debtor, the Chapter 13 Trustee and all creditors and other parties of interest 

herein. 

/s/ Christopher M. Winslow

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