Laura T. Alridge (VSB #92593)

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: Michelle E. Williams Case No. 18-35407-KRH

 Debtor Chapter 13

Address: 3212 Kim Drive 

Richmond,VA 23224

Last four digits of Social Security No: xxx-xx-4902(Debtor)

NOTICE OF MOTION FOR HARDSHIP DISCHARGE

The above named Debtor, by counsel, has filed a Motion for Hardship Discharge 

with the Court pursuant to 11 U.S.C. § 1328(b). 

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 IN OPPOSITION TO THIS MOTION AND SUPPORTING 

MEMORANDUM ARE FILED WITH THE CLERK OF COURT AND SERVED ON THE 

MOVING PARTY WITHIN 21 DAYS OF THE SERVICE OF THIS NOTICE, THE 

COURT MAY DEEM ANY OPPOSITION WAIVED AND TREAT THE MOTION AS 

CONCEDED. 

A HEARING ON THE ABOVE REFERENCE MOTION IS SCHEDULED 

FOR: November 29, 2023 at 12:00 p.m. before the Honorable Kevin R. 

Huennekens, United States Bankruptcy Court, 701 E. Broad Street, Room 5100, 

Richmond, VA 23219.

The written response in opposition to this motion must be filed with the clerk of 

court at the address shown below. If you mail your 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.

Case 18-35407-KRH Doc 82 Filed 10/31/23 Entered 10/31/23 13:44:53 Desc Main

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Clerk of Court

United States Bankruptcy Court

701 E. Broad Street, Suite 4000

Richmond, VA 23219-3515

 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 26, 2023 Respectfully submitted,

Michelle E. Willliams

By Counsel:

/s/ Laura T. Alridge

Laura T. Alridge (VSB #92593)

Boleman Law Firm, P.C.

P. O. Box 11588 

Richmond, Virginia 23230-1588

Telephone: (804) 358-9900

Counsel for Debtor

CERTIFICATE OF SERVICE

I certify that on October 26, 2023, I have transmitted a true copy of the foregoing 

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

Chapter 13 trustee, the United States Trustee if other than by the electronic means 

provided for at Local Bankruptcy Rule 2002-1, and to all creditors and parties in interest 

of the mailing matrix attached hereto.

/s/ Laura T. Alridge

Counsel for Debtor

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Laura T. Alridge (VSB #42549)

Boleman Law Firm, P.C.

272 Bendix Road, Suite 330

Virginia Beach, VA 23452

Telephone (757) 313-3000

Counsel for Debtor

IN THE UNITED STATES BANKRUPTCY COURT

Eastern District of Virginia

Richmond Division

In re: Michelle E. Williams

Debtor

Case No. 18-35407-KRH

Chapter 13

MOTION FOR HARDSHIP DISCHARGE AND

MEMORANDUM IN SUPPORT THEREOF

COMES NOW Michelle E. Williams (the “Debtor”), by counsel, pursuant to 11 

U.S.C. § 1328(b) and files the following Motion for Hardship Discharge, and affirmatively 

states as follows:

Jurisdiction

1. Jurisdiction of this Court over the instant matter is based upon 28 U.S.C. 

§§1334 and 157 in that this action arises in and relates to the bankruptcy case of the 

Debtor.

2. This proceeding is a core proceeding under 28 U.S.C. §157(b)(2)(A).

3. Venue is proper pursuant to 28 U.S.C. §1409.

Background Facts

4. On October 26, 2018, the Debtor filed a petition under Chapter 13 of the 

Bankruptcy Code. Suzanne E. Wade is the Chapter 13 Trustee in this case (the 

“Trustee”). 

5. The Modified Chapter 13 Plan was filed on September, 18, 2019 and

confirmed on April 10, 2019.

6. In the instant case, the Modified Chapter 13 Plan called for $ 175.00 per 

month for 4 months, and $ 225.00 for 56 months, for a total funding of $ 13,300.00.

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Discussion

7. Pursuant to 11 U.S.C. § 1328(b), Debtor must demonstrate to the Court 

that (1) her failure to complete plan payments is due to circumstances for which she

should not justly be held accountable, (2) the value of property distributed under the 

plan to unsecured creditors is not less than what would have been paid to each creditor 

if her estate had been liquidated under a Chapter 7 case, and (3) modification of the 

plan under 11 U.S.C. § 1329 is not practicable.

Argument

8. The Debtor is not currently employed full time, and is unable to afford to 

bring her case current with the Trustee. She is no longer receiving unemployment 

benefits and has used a

9. At the time of Debtor’s Chapter 13 filing, Debtor did not possess any 

assets that would result in any distribution to unsecured creditors in a Chapter 7 

bankruptcy case. The Chapter 13 Trustee has not paid any distribution to the unsecured 

creditors, however the unsecured creditors have not been paid less than what they 

would have received in a Chapter 7 Bankruptcy.

10. Because Debtor is in the 60th month of her case, a modified plan is not 

feasible.

11. The Debtor has satisfied all requirements necessary for discharge under 

11 U.S.C. § 1328(b).

WHEREFORE, for the foregoing reasons, the Debtor, by counsel, respectfully 

requests this Honorable Court to enter an Order granting the Debtor a Discharge 

pursuant to 11 U.S.C. Section 1328(b) and grant such other relief as may be just and 

Case 18-35407-KRH Doc 82 Filed 10/31/23 Entered 10/31/23 13:44:53 Desc Main

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appropriate.

Michelle E. Williams

By: /s/ Laura T. Alridge

Laura T. Alridge (VBS #42549)

Boleman Law Firm, P.C.

P.O. Box 11588

Richmond, VA 23230

Telephone (804)358-9900

Counsel for Debtor

CERTIFICATE OF SERVICE

I certify that on October 31, 2023 I have transmitted a true copy of the foregoing 

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

Chapter 13 trustee, the United States trustee if other than by the electronic means 

provided for at Local Bankruptcy Rule 2002-1, and to all creditors and parties in interest 

on the mailing matrix attached hereto.

/s/ Laura T. Alridge

Counsel for Debtor

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ADT Security

RE: Bankruptcy

PO Box 650485

Dallas, TX 75265

American Web Loan

Re: Bankruptcy

522 N. 14th St. #130

Ponca City, OK 74601

Ashley Village Community Assoc

7231 Forest Avennue

Suite 102

Richmond, VA 23226

AT&T

Attention: Bankruptcy Dept.

P.O. Box 536216

Atlanta, GA 30353

Beachbody

P.O. Box 406

Farmingdale, NY 11735

Big Valley Financial

PO Box 163

Finley, CA 95435

Boulders Ambluatory Surgery

1115 Boulders Parkway

Suite 210

Richmond, VA 23225

BWW Law Group, LLC

8100 Three Chopt Rd, Suite 240

Henrico, VA 23229

Cameo Dragon

416 East Main Street

Richmond, VA 23219

Capital One Bank USA NA

PO Box 30281

Salt Lake City, UT 84130

CJW Medical Center

PO Box 13620

Richmond, VA 23225

Commonwealth Anesthesia Assoc.

Attn: Bankruptcy Dept.

PO Box 35808

Richmond, VA 23235

County of Chesterfield

Treasurer

P.O. Box 40

Chesterfield, VA 23832

Credit One Bank

PO Box 60500

San Gabriel, CA 91776-0500

Dept of Ed/Navient

PO Box 9635

Wilkes Barre, PA 18773

DirecTV

Attn: Bankruptcy Claims

PO Box 6550

Englewood, CO 80155

Edward S. Whitlock

10160 Staples Mill Road

Suite 105

Glen Allen, VA 23060

First Premier Bank

Attn: Bankruptcy Dept.

PO Box 5524

Sioux Falls, SD 57117-5524

First Virginia

6785 Bobcat Way

Suite 200

Dublin, OH 43016

GEICO

One GEICO Blvd.

Fredericksburg, VA 22412-0001

IC Systems

444 Hwy 96 East

PO Box 64137

Saint Paul, MN 55164-0137

Jag Construction

5907 Blackjack Oak Court

Richmond, VA 23234

Keith Yacko, Esq.

McMichael Taylor Gray, LLC

3550 Engineering Dr., Ste. 260

Peachtree Corners, GA 30092

Lafayette, Ayers & Whitlock

10160 Staples Mill Rd

Ste 105

Glen Allen, VA 23060

LVNV Funding LLC

c/o Resurgent Capital Services

PO Box 10587

Greenville, SC 29603-0587

New Generations Federal Credit

Attn: Bankruptcy Dept.

1700 Robin Hood Road

Richmond, VA 23220

NTelos

401 Spring Lane, Suite 300

P.O. Box 1990

Waynesboro, VA 22980

OrthoVirginia

P.O. Box 35725

Richmond, VA 23235-0725

Public Savings Bank

1 Church Street

Rockville, MD 20850

Radiology Assoc. of Richmond

2602 Buford Rd.

Richmond, VA 23235

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Rushmore Loan Management Servi

P.O. Box 55004

Irvine, CA 92619-2708

Strayer University

Re: Bankruptcy

11501 Nuckols Road

Glen Allen, VA 23060

Wells Fargo Home Mortgage

3480 Stateview Blvd

Fort Mill, SC 29716

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