UNTED STATES BANKRUPTCY COURT

FOR THE EASTERN DISTRICT OF VIRGINIA

Alexandria Division

____________________________________

In Re: :

:

THOMAS G. JEWELL, : Case No. 17-11625-KHK

:

Debtor. :

____________________________________ :

:

DOROTHY M. JEWELL, AS BENEFICIARY :

OF THE CLARENCE G. JEWELL TRUST :

:

Movant, :

:

v. :

:

THOMAS G. JEWELL, :

:

Respondent. :

_____________________________________ :

NOTICE OF MOTION TO EXTEND TIME TO FILE 

OBJECTION TO CONFIRMATION OF CHAPTER 11 PLAN

Dorothy M. Jewell, as beneficiary of the Clarence G. Jewell Trust, a party in interest in 

this case, has filed the attached papers with the Court to extend the deadline to object to the 

confirmation of the Chapter 11 plan. 

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.) 

Under Local Bankruptcy Rule 9013-1, unless a written response to this motion and 

supporting memorandum are filed with the Clerk of the Court and served on the moving party 

within 14 days of 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.

If you mail your response to the Court for filing, you must mail it early enough so the 

Court will receive it before the date stated above. You must also send a copy to: 

Case 17-11625-KHK Doc 55 Filed 09/08/17 Entered 09/08/17 16:32:46 Desc Main

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United States Bankruptcy Court

Alexandria Division 

200 S. Washington St.

Alexandria, Virginia 22314-5405

(Address for filing)

Chong C. Park, Esquire 

Clark, Park & Dennis, P.C.

Market Station

108-E South Street, S.E.

Leesburg, Virginia 20175

cpark@theclarkfirm.com

Counsel for Movant 

Capital One

Attn: General Correspondence

P.O. Box 30285 

Salt Lake City, UT 84130-0285

Clarence G. Jewell Trust

c/o Frank Bredimus, Esquire

The Law Office of Frank Bredimus

P.O. Box 535

Hamilton, Virginia 20159

Counsel for Debtor/ Trustee

Credit One Bank

P.O. Box 98873

Las Vegas, NV 89193-8873

Jack Frankel, Esquire

Office of the U.S. Trustee

115 South Union Street 

Suite 210

Alexandria, Virginia 22314

Judy A. Robins, Esquire

Office of the U.S. Trustee

115 South Union Street

Suite 210

Alexandria, Virginia 22314

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M. Christine Maggard, Esquire

Brock & Scott, PLLC

484 Viking Drive, Suite 203

Virginia Beach, VA 23452

Frank Bredimus, Esquire

The Law Office of Frank Bredimus

P.O. Box 535

Hamilton, Virginia 20159

fbredimus@aol.com

Counsel for Debtor

If no timely response has been filed opposing the motion, the Court may grant the 

motion.

If you or your attorney do not take these steps, the Court may decide that you do not 

oppose and may enter an order granting the motion. 

Dated: September 8, 2017

Respectfully submitted,

DOROTHY M. JEWELL, as beneficiary of the 

Clarence G. Jewell Trust,

By Counsel,

______/s/ Chong C. Park_______

Chong C. Park, Esq., VSB 45733

Clark, Park & Dennis, P.C. 

Market Station

108-E South Street, S.E.

Leesburg, Virginia 20175

Tel (703) 443-0001

Fax (703) 443-1081

cpark@theclarkfirm.com

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CERTIFICATE OF SERVICE

I HEREBY CERTIFY that I have on this 8th day of September 2017, caused a copy of 

the foregoing Notice of Motion for Extension of Time to File Objection to Confirmation of 

Chapter 11 Plan to be served on all necessary parties by electronically filing the foregoing with 

the Clerk of the Court using CM/ECF System, and/or by mailing via U.S. First-Class Mail to the 

following:

Capital One

Attn: General Correspondence

P.O. Box 30285 

Salt Lake City, UT 84130-0285

Clarence G. Jewell Trust

c/o Frank Bredimus, Esquire

The Law Office of Frank Bredimus

P.O. Box 535

Hamilton, Virginia 20159

Counsel for Debtor/ Trustee

Credit One Bank

P.O. Box 98873

Las Vegas, NV 89193-8873

Jack Frankel, Esquire

Office of the U.S. Trustee

115 South Union Street 

Suite 210

Alexandria, Virginia 22314

M. Christine Maggard, Esquire

Brock & Scott, PLLC

484 Viking Drive, Suite 203

Virginia Beach, VA 23452

Frank Bredimus, Esquire

The Law Office of Frank Bredimus

P.O. Box 535

Hamilton, Virginia 20159

fbredimus@aol.com

Counsel for Debtor

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Judy A. Robins, Esquire

Office of the U.S. Trustee

115 South Union Street

Suite 210

Alexandria, Virginia 22314

___/s/ Chong C. Park__________

Chong C. Park

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UNTED STATES BANKRUPTCY COURT

FOR THE EASTERN DISTRICT OF VIRGINIA

Alexandria Division

____________________________________

In Re: :

:

THOMAS G. JEWELL, : Case No. 17-11625-KHK

:

Debtor. :

____________________________________ :

:

DOROTHY M. JEWELL, AS BENEFICIARY :

OF THE CLARENCE G. JEWELL TRUST :

:

Movant, :

:

v. :

:

THOMAS G. JEWELL, :

:

Respondent. :

_____________________________________ :

MOTION TO EXTEND TIME TO FILE OBJECTION TO CONFIRMATION 

OF CHAPTER 11 PLAN AND MEMORANDUM IN SUPPORT THEREOF

COMES NOW, Movant DOROTHY M. JEWELL, as beneficiary of the Clarence G. 

Jewell Trust, by counsel, and moves this Court for an extension of time to file Movant’s

Objection to Confirmation of Chapter 11 Plan, in this case. In support thereof, Ms. Jewell states 

as follows:

1. Dorothy M. Jewell is the sole beneficiary of The Clarence G. Jewell Trust, and is 

also a party in interest in this case. 

2. Mrs. Jewell is also a creditor in this case as the petitioner of a lawsuit filed against

the Debtor in state court.

3. On Friday August 25, 2017, Mrs. Jewell, by counsel, received the Debtor’s 

Suggestion of Bankruptcy notifying Mrs. Jewell that the Debtor filed for chapter 11 bankruptcy 

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on May 12, 2017 and that all claims were subject to an automatic stay. Up to the date of 

receiving the Debtor’s bankruptcy suggestion, Mrs. Jewell had not received any notification that 

the Debtor had filed for chapter 11 bankruptcy. 

4. On Tuesday August 29, 2017, Mrs. Jewell’s counsel became aware of a

confirmation hearing on the Debtor’s Plan of Reorganization (the “Plan”), which was scheduled 

to take place on that same day. Also on August 29, 2017, counsel for Mrs. Jewell learned that 

the matter was continued to October 24, 2017. 

5. Unknown to Mrs. Jewell, the deadline for all creditors and parties in interest to 

file their objections to the Plan was August 22, 2017. Mrs. Jewell never received notice of the 

confirmation hearing from the Debtor because the Debtor has been sending notification of the 

proceedings to himself as the trustee. 

6. After learning of the bankruptcy proceedings and obtaining a copy of the Debtor’s 

proposed plan, Mrs. Jewell’s counsel learned that the Clarence G. Jewell Trust (the “Trust”) is 

identified in the petition as a creditor for a “loan” that the Debtor made to himself while serving 

in his fiduciary capacity as trustee of the Trust.

7. Because Mrs. Jewell is the sole beneficiary of the trust and the Debtor serves the 

dual role of both debtor and the trustee who authorized the “loan”, it is paramount that Mrs. 

Jewell be provided with notice of the proceedings, an opportunity to be heard, and the 

opportunity to protect her interest through an objection. Accordingly, Mrs. Jewell requests that 

the deadline for filing an objection to the Debtor’s Plan be extended to a time sufficient to allow 

her to object to the Plan. 

WHEREFORE, Dorothy M. Jewell, as beneficiary of the Clarence G. Jewell Credit 

Shelter Trust, respectfully requests that this Court extend the deadline to object to the 

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confirmation of Debtor’s Chapter 11 Plan of Reorganization to a time sufficient to allow her to 

object to the Plan and grant such other relief as it deems just and proper.

Respectfully submitted,

DOROTHY M. JEWELL, as beneficiary of 

The Clarence G. Jewell Trust,

By Counsel,

______/s/ Chong C. Park_______

Chong C. Park, Esq., VSB 45733

Clark, Park & Dennis, P.C.

Market Station

108-E South Street, S.E.

Leesburg, Virginia 20175

Tel (703) 443-0001

Fax (703) 443-1081

cpark@theclarkfirm.com

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that I have on this 8th day of September 2017, caused a copy of 

the foregoing Motion to Extend time to Object to Confirmation of Chapter 11 Plan and 

Memorandum in Support Thereof to be served on all necessary parties by electronically filing the 

foregoing with the Clerk of the Court using CM/ECF System, and/or by mailing via U.S. FirstClass Mail to the following:

Capital One

Attn: General Correspondence

P.O. Box 30285 

Salt Lake City, UT 84130-0285

Clarence G. Jewell Trust

c/o Frank Bredimus, Esquire

The Law Office of Frank Bredimus

P.O. Box 535

Hamilton, Virginia 20159

Counsel for Debtor/ Trustee

Credit One Bank

P.O. Box 98873

Las Vegas, NV 89193-8873

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Jack Frankel, Esquire

Office of the U.S. Trustee

115 South Union Street 

Suite 210

Alexandria, Virginia 22314

M. Christine Maggard, Esquire

Brock & Scott, PLLC

484 Viking Drive, Suite 203

Virginia Beach, VA 23452

Frank Bredimus, Esquire

The Law Office of Frank Bredimus

P.O. Box 535

Hamilton, Virginia 20159

fbredimus@aol.com

Counsel for Debtor

Judy A. Robins, Esquire

Office of the U.S. Trustee

115 South Union Street

Suite 210

Alexandria, Virginia 22314

___/s/ Chong C. Park__________

Chong C. Park

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