UNITED STATES BANKRUPTCY COURT

EASTERN DISTRICT OF VIRGINIA

 Richmond Division

In re: 

 

Demetrice Antonio Jones 

Cheryl Dionne Jones Case No. 15-35268-KLP

 

Debtors Chapter 13

21500 Court St. 

S. Chesterfield, VA 23803 AP No. 15-03459

 

Last four digits of Social Security or Individual Tax-payer 

Identification (ITIN) No(s)., (if any): 8179, 2467

v.

Old Towne Motors, Inc. 

Defendants 

NOTICE OF MOTION 

Debtor(s) have filed papers with the court to Shorten Time for Filing Answers to 

Motion to Recover Property of the Bankruptcy Estate Pursuant to 11 U.S.C. § 362 (a).

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 motion (or objection), 

or if you want the court to consider your views on the motion (or objection), then on or 

before November 10, 2015 at 10:30 a.m., you or your attorney must:

[ X] 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 on or before the date stated above.

Clerk of Court

United States Bankruptcy Court

701 East Broad Street 

Richmond, VA 23219

You must also mail a copy to:

Brian K. Stevens, Esquire

Case 15-35268-KLP Doc 16 Filed 11/03/15 Entered 11/03/15 13:29:51 Desc Main

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The American Law Group, Inc.

2312 Boulevard, Colonial Heights, VA 23834

[ ] Attend a hearing to be scheduled at a later date. You will receive separate 

notice of hearing. If no timely response has been filed opposing the 

relief requested, the court may grant the relief without holding a 

hearing.

[X] Attend the hearing on the motion (or objection) scheduled to be held on 

November 10, 2015 at 10:30 at the United States Bankruptcy Court, 701

East Broad Street, Crtrm 5100 Richmond, VA 23219.

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 or objection and may enter an order granting 

that relief.

Date: November 3, 2015 Signature, name, address, and telephone 

number of person giving notice:

/s/ Brian K. Stevens

Brian K. Stevens, Esq.

The America Law Group, Inc.

2312 Boulevard

Colonial Heights, VA 23834

804-921-9244

Counsel for Demetrice Antonio Jones and 

Cheryl Dionne Jones 

Certificate of Service

I hereby certify that I on November 3, 2015, I have mailed or hand-delivered a true copy 

of the foregoing Notice of Motion (or Objection) to the Defendant, Old Towne Motors, 

Inc., William David Mueller, Registered Agent, 544 East Washington Street, Petersburg, 

VA 23803.

/s/ Brian K. Stevens

Brian K. Stevens, Esq.

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UNITED STATES BANKRUPTCY COURT

EASTERN DISTRICT OF VIRGINIA

 Richmond Division

In re: 

 

Demetrice Antonio Jones 

Cheryl Dionne Jones Case No. 15-35268-KLP

 

Debtors Chapter 13

21500 Court St. 

S. Chesterfield, VA 23803 AP No. 15-03459

 

Last four digits of Social Security or Individual Tax-payer 

Identification (ITIN) No(s)., (if any): 8179, 2467

v.

Old Towne Motors, Inc. 

Defendants 

MOTION TO SHORTEN TIME FOR RESPONSES TO DEBTOR’S 

NOTICE OF DEBTOR’S MOTION TO RECOVER PROPERTY OF THE 

BANKRUPTCY ESTATE 

COMES NOW, the Debtor, by counsel, and as and for their Motion To Shorten 

Time For Responses to Debtor’s Notice of Debtor’s Motion to Recover Property of the 

Bankruptcy Estate pursuant to U.S.C. §362(a) , and states as follows:

1. On November 3, 2015, the Debtor filed a Motion to Recover Property of 

the Bankruptcy Estate pursuant to U.S.C. §362(a)

2. To date there has been no response or objection to the Motion.

WHEREFORE, the Debtors respectfully request that the Court enter an Order shortening 

the time for the filing of responses to Debtor’s Motion to Recover Property of the Bankruptcy 

Estate, and for such other relief as the Court may deem appropriate.

Demetrice Antonio Jones and 

Cheryl Dionne Jones

By /s/ Brian K. Stevens

Brian K. Stevens, Esq.

The America Law Group, Inc.

2312 Boulevard

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Colonial Heights, VA 23834

804-520-2428

Certificate of Service

I hereby certify that I on November 3, 2015, have mailed or hand-delivered a true copy of 

the foregoing Notice of Motion (or Objection) to the Defendant, Old Towne Motors, Inc., 

William David Mueller, Registered Agent, 544 East Washington Street, Petersburg, VA 

23803.

/s/ Brian K. Stevens

Brian K. Stevens, Esq.

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