Louis J. Ebert (Bar No. 17527)

Rosenberg Martin Greenberg, LLP

25 South Charles Street, Suite 2115

Baltimore, MD 21201

(410) 649-4995

Attorneys for RL BB ACQ III-MD SHP, LLC

IN THE UNITED STATES BANKRUPTCY COURT

FOR THE EASTERN DISTRICT OF VIRGINIA

RICHMOND DIVISION

In re: *

LAMEES ALROMANI, * Case No. 16-13854

Debtor * (Chapter 7)

* * * * * * * * * * * * * * * * * * * * * * * * * * * * * * *

MOTION TO EXTEND TIME TO FILE A COMPLAINT

TO DETERMINE THE DISCHARGEABILITY OF CERTAIN DEBTS

RL BB ACQ III-MD SHP, LLC, assignee of RL BB Acquisition, LLC (“RL BB”), by its

undersigned attorney, hereby files this motion (the “Motion”) to extend the time to file a

complaint to determine the dischargeability of certain debts owed by Lamees Alromani (the

“Debtor”) to RL BB pursuant to Rule 4007 of the Federal Rules of Bankruptcy Procedure. In

support of the Motion, RL BB respectfully represents as follows:

1. On November 10, 2016, the Debtor filed a voluntary petition under Chapter 11 of

Title 11 of the United States Code (the “Bankruptcy Code”) commencing the instant proceeding.

2. H. Jason Gold has been appointed the Chapter 7 Trustee of the Debtor’s estate.

3. The deadline for filing a complaint to determine the dischargeability of certain

debts under Section 523 of the Bankruptcy Code is currently set for February 10, 2017.

4. RL BB holds a judgment against the Debtor, and others, in excess of three million

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dollars.

5. RL BB is currently investigating the Debtor’s financial and business affairs as

well as her entitlement to a discharge of the debt due and owing RL BB. However, RL BB

requires more time to make a final determination.

6. Therefore, RL BB requests that the Court extends the deadline to object to the

dischargeability of certain debts through and including April 10, 2017 to give RL BB a time in

which to investigate and assess the Debtor’s entitlement to the discharge of certain debts.

7. RL BB has not previously requested an extension of time in connection with this

case.

8. RL BB reserves the right to request an additional extension of time in this case.

9. This Motion need not be accompanied with a memorandum of points and

authorities pursuant to Local Bankruptcy Rule 9013-1 (G).

WHEREFORE, RL BB respectfully moves this Court to extend the time for RL BB to

file a complaint to determine the dischargeability of certain debts pursuant to 11 U.S.C. § 523

through and including April 10, 2017, with leave to request additional extensions, and for such

other and further relief as the Court may deem appropriate under the circumstances.

Dated: February 8, 2017 /s/ Louis J. Ebert

Louis J. Ebert (Bar No. 17527)

Rosenberg Martin Greenberg, LLP

25 South Charles Street, Suite 2115

Baltimore, MD 21201

(410) 649-4995

Attorneys for RL BB ACQ III-MD SHP, LLC

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NOTICE OF MOTION TO EXTEND TIME TO FILE A COMPLAINT TO DETERMINE

THE DISCHARGEABILITY OF CERTAIN DEBTS AND NOTICE OF MOTION

RL BB ACQ III-MD SHP, LLC, assignee of RL BB Acquisition, LLC (“RL BB”), by

counsel, has filed papers with the Court to extend the deadline to object to the dischargeability of

certain debts through and including April 10, 2017 (the “Motion”).

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. You must file a response as outlined below if you oppose

this motion within 14 days after service of this Notice or February 25, 2017, whichever is

later.

1. File with the Court, at the address shown below, a written response pursuant to

Local Bankruptcy Rule 9013-1. If you mail your response to the Court for filing, you must mail

it early enough so that the Court will receive it on or before the date stated above.

Clerk of Court

United States Bankruptcy Court

1100 East Main Street, Suite 301

Richmond, VA 23219

2. You must also mail a copy to:

Louis J. Ebert

Rosenberg Martin Greenberg, LLP

25 S. Charles Street, Suite 2115

Baltimore, MD 21201

H. Jason Gold

Nelson Mullins Riley & Scarborough LLP

1101 Constitution Avenue, N.W., Suite 900

Washington, DC 20001

Office of the U.S. Trustee

600 East Main Street, Suite 301

Richmond, VA 23219

3. No hearing is scheduled at this time. You will receive separate notice if a hearing

is scheduled.

NOTICE

UNDER LOCAL BANKRUPTCY RULE 9013-1, UNLESS A WRITTEN RESPONSE TO

THE MOTION AND SUPPORTING MEMORANDUM ARE FILED WITH THE CLERK

OF THE COURT AND SERVED ON THE MOVING PARTY WITHIN 14 DAYS OF

THE SERVICE OF THIS NOTICE OBJECTING TO THE RELIEF REQUESTED, THE

COURT MAY DEEM ANY OPPOSITION WAIVED, TREAT THE MOTION AS

CONCEDED, AND ISSUE AN ORDER GRANTING THE REQUESTED RELIEF

WITHOUT FURTHER NOTICE OR HEARING.

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Dated: February 8, 2017 /s/ Louis J. Ebert

Louis J. Ebert (Bar No. 17527)

Rosenberg Martin Greenberg, LLP

25 South Charles Street, Suite 2115

Baltimore, MD 21201

(410) 649-4995

Attorneys for RL BB ACQ III-MD SHP, LLC

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on this 8th day of February, 2017, a copy of the foregoing Motion

to extend time to file a complaint to determine the dischargeability of certain debts, notice

thereof, and a proposed order granting said relief was served electronically via CM/ECF and/or

by first class mail, postage prepaid, on:

Lamees Alromani

8901 Gallant Green Drive

McLean, VA 22102

H. Jason Gold

Nelson Mullins Riley & Scarborough LLP

101 Constitution Avenue, N.W.

Suite 900

Washington, DC 20001

Office of the U.S. Trustee

600 East Main Street, Suite 301

Richmond, VA 23219

Richard Owen Bolger

Bolger Law Firm, PLLC

10347 Democracy Lane

Fairfax, VA 22030

Bank of America

PO Box 26012

Greensboro, NC 27420

Citi

P.O. Box 6190

Sioux Falls, SD 57117

/s/Louis J. Ebert

Louis J. Ebert

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Louis J. Ebert (Bar No. 17527)

Rosenberg Martin Greenberg, LLP

25 South Charles Street, Suite 2115

Baltimore, MD 21201

(410) 649-4995

Attorneys for RL BB ACQ III-MD SHP, LLC

IN THE UNITED STATES BANKRUPTCY COURT

FOR THE EASTERN DISTRICT OF VIRGINIA

RICHMOND DIVISION

In re: *

LAMEES ALROMANI, * Case No. 16-13854

Debtor * (Chapter 7)

* * * * * * * * * * * * * * * * * * * * * * * * * * * * * * *

ORDER EXTENDING TIME TO FILE A COMPLAINT

TO DETERMINE THE DISCHARGEABILITY OF CERTAIN DEBTS

This matter came before the Court upon RL BB ACQ III-MD SHP, LLC’s, assignee of

RL BB Acquisition, LLC (“RL BB”) motion (the “Motion”) to extend the time to file a

complaint to determine the dischargeability of certain debts owed by Lamees Alromani (the

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“Debtor”), by counsel, and within the time allowed pursuant to Bankruptcy rules 4007(c) and

9006(b). It appearing that RL BB has set forth valid grounds for the requested extension, no

objection or response having been filed with this Court, and proper notice of the Motion was

served, it is hereby ORDERED:

1. The Motion is hereby GRANTED.

2. The time for RL BB to file a complaint pursuant to 11 U.S.C. 523 objecting to the

Debtor’s discharge of certain debts is hereby extended through and including April 10, 2017.

3. RL BB is granted leave to apply for a further extension of this deadline.

4. Upon entry, the Clerk is directed to send a copy of this Order to all parties on the

service list attached hereto.

Entered:

United States Bankruptcy Judge

I ask for this:

/s/ Louis J. Ebert

Louis J. Ebert (Bar No. 17527)

Rosenberg Martin Greenberg, LLP

25 South Charles Street, Suite 2115

Baltimore, MD 21201

(410) 649-4995

Attorneys for RL BB ACQ III-MD SHP, LLC

CERTIFICATION

I hereby certify that this Order Extending Deadline for Objecting to Dischargeability of

Certain Debts has been served on or endorsed by all necessary parties on February 8, 2017.

/s/ Louis J. Ebert

Louis J. Ebert

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SERVICE LIST

Lamees Alromani

8901 Gallant Green Drive

McLean, VA 22102

H. Jason Gold

Nelson Mullins Riley & Scarborough LLP

101 Constitution Avenue, N.W., Suite 900

Washington, DC 20001

Office of the U.S. Trustee

600 East Main Street, Suite 301

Richmond, VA 23219

Richard Owen Bolger

Bolger Law Firm, PLLC

10347 Democracy Lane

Fairfax, VA 22030

Bank of America

PO Box 26012

Greensboro, NC 27420

Citi

P.O. Box 6190

Sioux Falls, SD 57117

4850-8072-1986, v. 1

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