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James E. Kane (VSB #30081) 

KANE & PAPA, P.C. 

1313 East Cary Street 

Richmond, VA 23219 

(804) 225-9500 (phone) 

(804) 225-9598 (fax) 

Counsel for Debtor 

IN THE UNITED STATES BANKRUPTCY COURT 

FOR THE EASTERN DISTRICT OF VIRGINIA 

Richmond Division 

 

IN RE: ) 

 ) 

ROSINA DENISE COOK ) Case No. 16-32472-KRH 

 ) Chapter 13 

 Debtor ) 

MOTION TO EXPEDITE HEARING ON AMENDED 

MOTION TO INCUR DEBT AND TO SHORTED NOTICE PERIOD 

 COMES NOW the Debtor, by counsel, and moves this Court to Expedite the Hearing on her 

Amended Motion to Incur Debt and to Shorten Notice Period, and in support thereof states as 

follows: 

 1. The Debtor filed this case under Chapter 13 of the U.S. Bankruptcy Code on May 

16, 2010. 

 2. The Debtor has applied for and Movement Mortgage, LLC has approved a loan to 

the Debtor in the amount of $378,826.00 plus interest at 3.625% per annum to be repaid with 360 

equal monthly payments of $2,296.00 for the refinancing of the loan on her home located at 8902 

Mansfield Woods Drive, Henrico, VA 23231. The closing costs are to be paid by the Debtor. 

3. The refinancing of the loan is in the best interest of the Debtor and will facilitate 

her ability to perform under her Chapter 13 Plan filed herein. 

4. The Debtor’s Chapter 13 Plan has been confirmed. 

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WHEREFORE, the Debtor respectfully requests that the Court expedite the hearing on 

the Amended Motion to Incur Debt, Shorten the Notice Period required for said Motion, and grant 

such other and further relief as is just and proper. 

Dated: May 27, 2020 ROSINA DENISE COOK 

 By: /s/ James E. Kane 

 Counsel 

James E. Kane (VSB #30081) 

KANE & PAPA, P.C. 

1313 East Cary Street 

Richmond, VA 23219 

(804) 225-9500 (phone) 

(804) 225-9598 (fax) 

Counsel for Debtor 

 

CERTIFICATION

 I, James E. Kane, pursuant to Local Rule 9013-1(N), do hereby certify that: 

 

 1. I have carefully examined the matter and concluded that there is a true need for 

an emergency hearing, 

 2. I have not created the emergency through any lack of due diligence. 

 3. I have made a bona fide effort to resolve the matter without hearing. 

By: /s/ James E. Kane__________ 

 James E. Kane 

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CERTIFICATE OF SERVICE 

I hereby certify that on May 27, 2020, I will electronically file the foregoing with the 

Clerk of Court using the CM/ECF system, which will then send a notification of such filing 

(NEF) to all parties registered to receive notice thereof and will mail the same by first class mail, 

postage pre-paid, to the parties on the attached list. 

/s/ James E. Kane 

Counsel for Debtor 

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IN THE UNITED STATES BANKRUPTCY COURT 

FOR THE EASTERN DISTRICT OF VIRGINIA 

Richmond Division 

 

IN RE: ) 

 ) 

ROSINA DENISE COOK ) Case No. 16-32472-KRH 

 ) Chapter 13 

 Debtor ) 

NOTICE OF MOTION AND HEARING 

 The above Debtor has filed papers with the Court to request an order to Expedite the 

hearing and to Shorten the Notice Period with respect to the Amended Motion to Incur Debt. 

 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 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 

written response pursuant to Local Bankruptcy Rule 9013-1(H)]. If you mail your 

request for a 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, to: 

Clerk of Court 

United States Bankruptcy Court 

701 East Broad Street 

Richmond, VA 23219 

You must also mail a copy to: 

James E. Kane, Esquire 

KANE & PAPA, P.C. 

1313 East Cary Street 

Richmond, Virginia 23219 

 Attend a hearing scheduled for June 3, 2020 at 12:00 p.m. at U.S. Bankruptcy 

Court, 701 East Broad Street, Room 5000, Richmond, VA 23219. If no 

timely response has been filed opposing the relief requested, the court may grant 

the relief without holding a hearing. 

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 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. 

Dated: May 27, 2020 ROSINA DENISE COOK 

 By: /s/ James E. Kane 

 Counsel 

James E. Kane (VSB #30081) 

KANE & PAPA, P.C. 

1313 East Cary Street 

Richmond, VA 23219 

(804) 225-9500 (phone) 

(804) 225-9598 (fax) 

Counsel for Debtor 

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CERTIFICATE OF SERVICE 

I hereby certify that on May 27, 2020, I will electronically file the foregoing with the 

Clerk of Court using the CM/ECF system, which will then send a notification of such filing 

(NEF) to all parties registered to receive notice thereof and will mail the same by first class mail, 

postage pre-paid, to the parties on the attached list. 

/s/ James E. Kane 

Counsel for Debtor 

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