IN THE UNITED STATES BANKRUPTCY COURT

FOR THE EASTERN DISTRICT OF VIRGINIA

Richmond Division

In re: Daquan Aku Reinhardt Case No. 16-35512-KLP

Debtor Chapter 13

DAQUAN AKU REINHARDT

Movant,

v.

JOY M. REINHARDT and

SUZANNE E. WADE, Trustee

Respondents

NOTICE OF MOTION FOR RELIEF FROM STAY

TO: Joy M. Reinhardt and Suzanne E. Wade:

The above named Movant, by counsel, has filed a Motion for Relief from the Stay in this 

bankruptcy case.

Pursuant to Rule 4001(a)-1(C) of the Local Rules of the US Bankruptcy Court of the 

Eastern District of Virginia, you have fourteen (14) days from the date of this Motion to file 

a written response and you must file such response with the Clerk of the US Bankruptcy 

Court, Richmond Division, 701 East Broad Street, Suite 4000, Richmond, VA 23219 and 

serve a copy on Movant's counsel, Deanna H. Hathaway, Hathaway Adair, P.C., 710 N. 

Hamilton St., Suite 200, Richmond VA 23221.

Deanna H. Hathaway (VSB #44150)

Hathaway Adair, P.C.

710 N. Hamilton St., Ste 200

Richmond, VA 23221

Telephone: 804-257-9944

Counsel for the Debtor

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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 and may enter an order granting that relief.

Respectfully submitted,

Daquan Aku Reinhardt

 By Counsel

 

By: /s/ Deanna H. Hathaway VSB #44150

Deanna H. Hathaway (VSB #44150)

Hathaway Adair, P.C.

710 N. Hamilton St., 210 

Richmond, Virginia 23221

Counsel for Movant

CERTIFICATE OF SERVICE

I certify that on March 14, 2017, a copy of this Notice of Motion has been

transmitted electronically through the Court's CM/ECF system or by first class mail to the 

following necessary parties: 

Joy M. Reinhardt

c/o Mary A. Napier, Esquire

BoykoNapier, PLLC

5807 Staples Mill Road

Henrico VA 23228

Counsel for Joy N. Reinhardt

Suzanne E. Wade, Trustee

P.O. Box 1780

Richmond VA 23218

Daquan Aku Reinhardt

5112 Timbercreek Drive 

Richmond, VA 23237

 /s/ Deanna H. Hathaway

 Counsel for Movant

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IN THE UNITED STATES BANKRUPTCY COURT

FOR THE EASTERN DISTRICT OF VIRGINIA

Richmond Division

In re: Daquan Aku Reinhardt Case No. 16-35512-KLP

Debtor Chapter 13

DAQUAN AKU REINHARDT

Movant,

v.

JOY M. REINHARDT and

SUZANNE E. WADE, Trustee

Respondents

MOTION FOR RELIEF FROM STAY

Comes now Daquan Aku Reinhardt (the “Debtor”), by counsel, and respectfully submits 

the following Motion for Relief from Stay ("Motion"), and in support thereof alleges and states 

as follows:

1. This Motion is filed pursuant to 11 U.S.C. section 362(d), Federal Rules of 

Bankruptcy Procedure 4001(a) and 9041, and Local Bankruptcy Rule 4001(a)-1, seeking relief 

from the automatic stay of 11 U.S.C. section 362.

2. This Court has jurisdiction pursuant to 28 U.S.C. sections 157 and 1334, and 

venue is appropriate pursuant to 28 U.S.C. sections 1408 and 1409.

3. This is a core proceeding within the meaning of the Bankruptcy Code.

4. On November 9, 2016, Debtor filed for an order for relief under Chapter 13 of the 

Bankruptcy Code protection pursuant to 11 U.S.C. § 101 et seq. (the “Petition Date”).

Deanna H. Hathaway (VSB #44150)

Hathaway Adair, P.C.

710 N. Hamilton St., Ste 200

Richmond, VA 23221

Telephone 804-257-9944

Counsel for Debtor

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5. The Debtor and his estranged wife, Joy D. Reinhardt, are parties to a domestic 

relations matter pending in the state court. Currently, a hearing on the issue of equitable

distribution is pending.

6. Pursuant to 11 U.S.C. 362 (b)(2)(a), the filing of the bankruptcy does not operate 

as a stay with respect to the determination of custody, support or visitation. However, the filing 

does operate as a stay as to the determination of division of property of the estate. 

7. The Debtor seeks relief from the automatic stay for the express purpose of having 

the pending state court matter proceed in its entirety without the need for further delay.

9. Joy M. Reinhardt, by counsel, is in support of this motion and a proposed consent 

order granting relief is attached hereto and has been submitted to the Court for entry. 

8. Pursuant to Local Bankruptcy Rule 9013-1(G), as there are no novel issues of law 

presented in this Motion and all applicable authority is set forth in the Motion, the Debtor 

requests that the requirement to submit a separate memorandum of law be waived.

WHEREFORE Daquan Aku Reinhardt respectfully requests that the Court enter an Order 

lifting the automatic stay as to so that the equitable distribution hearing can proceed as scheduled 

in state court or for such other relief the Court deems appropriate.

Respectfully submitted,

Daquan Aku Reinhardt

 By Counsel

 

By: /s/ Deanna H. Hathaway VSB #44150

Deanna H. Hathaway (VSB #44150)

Hathaway Adair, P.C.

710 N. Hamilton St., Ste 200

Richmond, Virginia 23221

Counsel for Movant

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CERTIFICATE OF SERVICE

I certify that on March 14, 2017, a copy of this Notice of Motion has been

transmitted electronically through the Court's CM/ECF system or by first class mail to the 

following necessary parties: 

Joy M. Reinhardt

c/o Mary A. Napier, Esquire

BoykoNapier, PLLC

5807 Staples Mill Road

Henrico VA 23228

Counsel for Joy N. Reinhardt

Suzanne E. Wade, Trustee

P.O. Box 1780

Richmond VA 23218

Daquan Aku Reinhardt

5112 Timbercreek Drive 

Richmond, VA 23237

 /s/ Deanna H. Hathaway

 Counsel for Movant

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