___________________________________

Janet M. Meiburger, VA Bar No. 31842

The Meiburger Law Firm, P.C.

1493 Chain Bridge Road, Suite 201

McLean, VA 22101

(703) 556-7871

Proposed Counsel for the Chapter 7 Trustee

IN THE UNITED STATES BANKRUPTCY COURT

FOR THE EASTERN DISTRICT OF VIRGINIA

Alexandria Division

IN RE:

NG GROUP, LLC

Debtor

)

)

)

) Case No. 17-11562-BFK

) Chapter 7

)

)

)

TRUSTEE’S MOTION FOR ENTRY OF ORDER 

REQUIRING PATRICK R. BLASZ TO SHOW CAUSE WHY 

HE SHOULD NOT BE FOUND TO BE IN CONTEMPT OF

COURT FOR FAILURE TO COMPLY WITH COURT ORDER

Janet M. Meiburger, Chapter 7 Trustee, by proposed counsel, hereby moves, pursuant to 

Federal Rules of Bankruptcy Procedure 9014 and 9020, for entry of an order requiring Patrick R. 

Blasz to show cause why he should not be found to be in contempt of court for failure to comply 

with the Order Imposing Sanctions (Docket No. 43). In support of this Motion, the Trustee states 

as follows:

1. The Debtor commenced this case by filing a voluntary petition for relief under 

Chapter 11 of the Bankruptcy Code on May 9, 2017 (the “Petition Date”). Patrick Blasz filed the 

case as counsel to the Debtor.

2. This case was converted to a Chapter 7 case on December 8, 2017 (Docket No. 

54). Janet M. Meiburger was appointed Chapter 7 Trustee on December 13, 2017 (Docket No. 

55). 

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3. On July 3, 2017, the Court entered an Order Imposing Sanctions (Docket No. 43) 

requiring Mr. Blasz to pay the balance of the retainer paid to him by the Debtor, in the 

approximate amount of $3,200.00, to the Chapter 7 Trustee when the case was converted. 

4. On January 31, 2018, the Trustee mailed a letter to Mr. Blasz requesting that he 

send the balance of his retainer by Friday, February 9, 2018. The Trustee included a copy of the 

notice of her appointment as Chapter 7 Trustee along with a copy of the Order Imposing 

Sanctions (Docket No. 43). Mr. Blasz contacted the Trustee in response to the letter, but he has 

not made any payment. 

WHEREFORE, Janet M. Meiburger, Chapter 7 Trustee, by proposed counsel, 

respectfully requests that the Court enter an order requiring Patrick R. Blasz to show cause why 

he should not be held in contempt of court for failure to comply with Order Imposing Sanctions

(Docket No. 43).

Respectfully submitted,

THE MEIBURGER LAW FIRM, P.C.

By: /s/ Janet M. Meiburger

Dated: April 6, 2018 Janet M. Meiburger, VSB No. 31842

The Meiburger Law Firm, P.C.

1493 Chain Bridge Road, Suite 201

McLean, VA 22101

(703) 556-7871

Proposed Counsel to the Chapter 7 Trustee

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CERTIFICATE OF SERVICE

I hereby certify that on this 6th day of April, 2018, I caused a true and correct copy of the 

foregoing Trustee’s Motion for Entry of Order Requiring Patrick R. Blasz to Show Cause Why 

He Should not be Found to be in Contempt of Court for Failure to Comply with Court Order to 

be served by ECF e mail pursuant to the applicable Standing Order of the Court, and by firstclass mail, postage prepaid, on the following:

Patrick R. Blasz

10224 Tamarack Drive

Vienna, VA 22182

Joseph A. Guzinski, Esq.

Office of the United States Trustee

115 South Union Street, Room 210

Alexandria, VA 22314

/s/ Janet M. Meiburger

Janet M. Meiburger

J:\Trustee\NG Group, LLC (17-11562)\Pleadings\Blasz.Show Cause Motion.1.doc

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