Daniel M. Press, VSB# 37123 

Chung & Press, P.C. 

6718 Whittier Ave., Suite 200 

McLean, VA 22101 

(703) 734-3800 

Counsel for Debtor

UNITED STATES BANKRUPTCY COURT 

EASTERN DISTRICT OF VIRGINIA 

(Alexandria Division) 

 ______ 

In re ) 

 ) 

MARY LOU ZIMMERMAN, ) 

 ) No. 16-10237-BFK 

 Debtor. ) Chapter 11 

__________________________________________) 

FINAL REPORT AND MOTION FOR FINAL DECREE, FOR ENTRY OF 

DISCHARGE, AND TO CLOSE CASE 

 COMES NOW Mary Lou Zimmerman (the “Debtor”), the reorganized debtor 

herein, by her undersigned counsel, and submits this Final Report, Motion for Final 

Decree, for Entry of Discharge, and to Close Case (the “Motion for Final Decree”). 

Contemporaneously herewith, the Debtor is also submitting a Final Account that should 

be considered in evaluating the Debtor’s Motion for Final Decree. 

 1. On January 21, 2016 (the “Petition Date”), the Debtor commenced his 

voluntary chapter 11 bankruptcy case. 

 2. By Order entered August 31, 2017, (the “Confirmation Order”), the Court 

confirmed the Debtor’s Plan of Reorganization (the “Plan”). 

 3. Subsequently, the Debtor has undertaken those steps necessary to 

substantially consummate and fully administer the confirmed Plan as provided under 

Section 1101(2) of Title 11 of the United States Code (the “Bankruptcy Code”). More 

specifically, the Debtor has commenced distribution under the Plan, and has completed 

payments to her creditors (except for the attorney’s fees pending court approval, for 

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which there are sufficient funds in escrow from the Debtor and her husband). Each of the 

requirements under Section 1101(2) of the Bankruptcy Code is summarized below. There 

has been substantial consummation of the Plan confirmed by the Court on August 31, 

2017. The property required to be transferred was transferred; the debtor has assumed 

the management of all the property dealt with by the plan; and the debtor has commenced 

and completed distribution under the plan. Each of these three requirements under 11 

USC §1101(2) is summarized below. 

I. Transfer of Property. 

 The Plan was funded by a contribution from Debtor’s husband, which was 

completed and paid. Accordingly, all property transfers anticipated by the Plan have 

been completed. 

II. Assumption by Debtor of Management of Property. 

 The plan provided for the debtor to stay in control of her assets after confirmation. 

Since the date of confirmation, the debtor has remained in control and has operated 

pursuant to the terms of the plan. 

III. Distributions. 

 On the effective date, September 15, 2017, the Debtor commenced and completed 

distributions under the plan. The Debtor has paid all administrative expenses that have 

come due (other than fees for Debtor’s counsel, which have been escrowed), all taxes are 

current, Debtor has made all payments under the plan due in accordance with Plan 

provisions and in the Final Report attached hereto as Exhibit A. The Debtor asks for 

approval of the Final Report. 

MOTION FOR FINAL DECREE 

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 As indicated above, the Debtor have substantially consummated the Plan as 

provided under Section 1101(2) of the Bankruptcy Code. To the best of the Debtor’s 

knowledge, all allowed administrative claims have been paid (other than the fees of 

Debtor’s counsel for which funds have been escrowed), and U.S. Trustee fee for the 

present quarter and the 4th quarter will be paid in conjunction with or prior to the 

approval of this motion. Debtor does not anticipate that there will be any further 

administrative claims sought by creditors. The Debtor has completed the transfer of all 

property to be transferred under the Plan. All pending motions, contested matters and 

adversary proceedings have been resolved or will be resolved concurrently with this 

motion. The Debtor will pay any outstanding quarterly fees to the Office of the United 

States Trustee through the fourth quarter of 2017 in conjunction with the Court’s 

approval of this motion. 

REQUEST FOR ENTRY OF DISCHARGE 

 Article VIII of the Plan provides that “Upon completion of all payments due to 

creditors, the Debtor shall be entitled to a discharge of and from all debts dischargeable 

under § 1141(d) of the Code.” The Debtor has made or escrowed all payments to 

creditors and unclassified claims (administrative expenses and priority taxes. 

Accordingly, Debtor is entitled to entry of her discharge. DEBTOR’S CERTIFICATION 

OF COMPLIANCE WITH 11 U.S.C. § 1141(d)(5) is being filed herewith. 

 WHEREFORE, Debtor respectfully seeks entry of an Order by this Court: (i) 

approving the Debtor’s final report; (ii) granting the Debtor a discharge; (iii) granting the 

Debtors' Motion for entry of a Final Decree in this case, and closing the case; and (iv) for 

such further relief as the Court deems just and appropriate. 

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 Dated: September 25, 2017. 

 Respectfully submitted, 

 _/s/ Daniel M. Press_____________ 

 Daniel M. Press, VSB 37123 

 Chung & Press, P.C. 

 6718 Whittier Ave., Suite 200 

 McLean, VA 22101 

 (703) 734-3800/(703) 734-0590 fax 

 dpress@chung-press.com 

CERTIFICATE OF SERVICE 

 This is to certify that on this 25th day of September, 2017, I caused the foregoing 

document to be served on the US Trustee and all persons requesting notice by CM/ECF, 

and by first class mail, postage prepaid, on all creditors on the attached matrix. 

 _/s/ Daniel M. Press_____________ 

 Daniel M. Press 

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 Label Matrix for local noticing United States Bankruptcy Court (p)BANK OF AMERICA 

 0422-1 200 South Washington Street PO BOX 982238 

 Case 16-10237-BFK Alexandria, VA 22314-5405 EL PASO TX 79998-2238 

 Eastern District of Virginia 

 Alexandria 

 Tue Sep 19 17:54:05 EDT 2017 

 CERASTES, LLC Capital One Internal Revenue Service 

 C O WEINSTEIN & RILEY, PS PO Box 30253 PO Box 7346 

 2001 WESTERN AVENUE, STE 400 Salt Lake City, UT 84130-0253 Philadelphia, PA 19101-7346 

 SEATTLE, WA 98121-3132 

 

 Lester Zimmerman Nordstrom Bank PNC Bank, National Association 

 935 Mackall Ave PO Box 13589 3232 Newmark Drive 

 Mc Lean, VA 22101-1617 Scottsdale, AZ 85267-3589 Miamisburg, OH 45342-5421 

 PNC Mortgage SLS Samuel I White PC 

 3232 Newmark Dr PO Box 636005 5040 Corporate Woods Dr 

 Miamisburg, OH 45342-5433 Littleton, CO 80163-6005 Virginia Beach, VA 23462-4377 

 US Bank, N.A., Trustee Daniel M. Press Judy A. Robbins 

 425 Walnut St Chung & Press, P.C. Office of the U.S. Trustee - Region 4 

 Cincinnati, OH 45202-3989 6718 Whittier Ave., Suite 200 115 South Union Street, Room 210 

 McLean, VA 22101-4531 Alexandria, VA 22314-3361 

 Mary Lou Zimmerman 

 1820 Fonthill Court 

 Mc Lean, VA 22102-4788 

 The preferred mailing address (p) above has been substituted for the following entity/entities as so specified 

 by said entity/entities in a Notice of Address filed pursuant to 11 U.S.C. 342(f) and Fed.R.Bank.P. 2002 (g)(4). 

 Bank of America 

 PO Box 982238 

 El Paso, TX 79998-2238 

 The following recipients may be/have been bypassed for notice due to an undeliverable (u) or duplicate (d) address. 

 (u)SPECIALIZED LOAN SERVICING LLC AS SERVICER (u)U.S. Bank National Association, as Trustee End of Label Matrix 

 Mailable recipients 15 

 Bypassed recipients 2 

 Total 17

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