Amanda Erin DeBerry (VSB#83805) 

Boleman Law Firm, P.C. 

P.O. Box 11588 

Richmond, VA 23230-1588 

Telephone (804) 358-9900 

Counsel for Debtor

IN THE UNITED STATES BANKRUPTCY COURT 

Eastern District of Virginia 

Richmond Division 

 

In re: Brian Wirt Bartlett

Debtor 

Case No. 18-31079-KRH

Chapter 13

Address: 4298 Pierce Road 

 Powhatan, VA 23139 

Last four digits of Social Security No: xxx-xx-6226 (Debtor) 

NOTICE OF MOTION FOR RELIEF FROM THE AUTOMATIC STAY AND HEARING

 The above named Debtor has filed a Motion for Relief from the Automatic Stay in 

this bankruptcy case. 

 Your rights may be affected. You should read these papers carefully and 

discuss them with your attorney, if you have one. 

 NOTICE IS HEREBY GIVEN that a hearing thereon will be held on the 

above-referenced Motion at the United States Bankruptcy Court, in the Honorable 

Kevin R. Huennekens’s Courtroom, 701 E. Broad Street, Room 5000, Richmond, 

VA 23219-3515, on November 14, 2018, at 11:00 a.m.

If you do not want the Court to grant the above-referenced Motion, then no later 

than 7 days before the date of the hearing, you or your attorney must: 

File with the Court a written answer explaining your position at: 

 Clerk of Court 

 United States Bankruptcy Court 

 701 E. Broad Street, Suite 4000 

 Richmond, VA 23219-3515 

 If you mail your response to the Court for filing, you must mail it to the address 

listed immediately above and early enough so that the Court will receive it within the 

time period stated above. 

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 You must also send a copy to:

 Boleman Law Firm, P.C. 

P.O. Box 11588 

Richmond, VA 23230-1588 

 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. 

Dated: October 31, 2018 BOLEMAN LAW FIRM, P.C. 

Counsel for Debtor 

 

 By: /s/ Amanda Erin DeBerry 

Amanda Erin DeBerry (VSB#83805) 

Boleman Law Firm, P.C. 

P.O. Box 11588 

Richmond, VA 23230-1588 

Telephone (804) 358-9900 

Counsel for Debtor 

CERTIFICATE OF SERVICE 

 I certify that on October 31, 2018 I have transmitted a true copy of the foregoing 

document electronically through the Court’s CM/ECF system or by mail to the Debtor 

the Chapter 13 trustee, and Paul Curley, Counsel for Tracy Bartlett, and to Tracy 

Bartlett at the following address: 

Tracy Bartlett 

2557 Mountainview Road 

Powhatan, VA 23139 

/s/ Amanda Erin DeBerry 

Counsel for Debtor

Case 18-31079-KRH Doc 22 Filed 10/31/18 Entered 10/31/18 15:23:04 Desc Main

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IN THE UNITED STATES BANKRUPTCY COURT 

Eastern District of Virginia 

Richmond Division 

In re: Brian Wirt Bartlett

Debtor 

Case No. 18-31079-KRH

Chapter 13

MOTION FOR RELIEF FROM THE AUTOMATIC STAY 

 Comes Now, Brian Wirt Bartlett (“Debtor”), by counsel, and moves this Honorable 

Court for relief from the Automatic Stay provided by 11 U.S.C. § 362 so that he may 

proceed with domestic relations proceedings in State Court, and in support thereof, 

states as follows: 

1. The Debtor filed for protection under Chapter 13 of the United States 

Bankruptcy Code on March 5, 2018. 

2. The Debtor filed a Chapter 13 Plan on March 7, 2018, which was 

confirmed by Order of the Court on May 15, 2018. 

3. The Debtor seeks to obtain a divorce from his wife, Tracy Bartlett (“Mrs. 

Bartlett”). 

4. Upon information and belief, the State Court will not proceed with any 

domestic relations proceedings without the stay being lifted. 

5. The relief requested is limited to allowing the divorce and related matters 

to proceed. Relief is not requested as to property of the estate, nor would 

the relief requested herein allow for execution of any State Court judgment 

on property of the estate without further Order of Court. 

Amanda Erin DeBerry (VSB#83805) 

Boleman Law Firm, P.C. 

P.O. Box 11588 

Richmond, VA 23230-1588 

Telephone (804) 358-9900 

Counsel for Debtor 

Case 18-31079-KRH Doc 22 Filed 10/31/18 Entered 10/31/18 15:23:04 Desc Main

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 Based upon these facts, the Debtor respectfully requests that the Court grant his 

Motion to Relief from the Automatic Stay pursuant to 11 U.S.C. § 362 so that he may 

proceed with divorce proceedings in the State Court and order such other and further 

relief as is just and proper. 

 Respectfully Requested, 

 Brian Wirt Bartlett 

 

 /s/ Amanda Erin DeBerry 

Amanda Erin DeBerry (VSB#83805) 

Boleman Law Firm, P.C. 

P.O. Box 11588 

Richmond, VA 23230-1588 

Telephone (804) 358-9900 

 Counsel for Debtor

CERTIFICATE OF SERVICE 

 I certify that on October 31, 2018 I have transmitted a true copy of the foregoing 

document electronically through the Court’s CM/ECF system or by mail to the Debtor 

the Chapter 13 trustee, and Paul Curley, Counsel for Tracy Bartlett, and to Tracy 

Bartlett at the following address: 

Tracy Bartlett 

2557 Mountainview Road 

Powhatan, VA 23139 

/s/ Amanda Erin DeBerry 

Counsel for Debtor

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