Madeline A. Trainor, Esq. VSB #18531 

Redmon Peyton & Braswell, LLP 

510 King Street, Suite 301 

Alexandria, VA 22314 

703-684-2000 

mtrainor@rpb-law.com 

Counsel for WizdomBridge, LLC 

IN THE UNITED STATES BANKRUPTCY COURT 

FOR THE EASTERN DISTRICT OF VIRGINIA 

Alexandria Division 

 

 ) 

In the Matter of ) 

 ) 

 PEDRO FELIPE VALDES ) Case No. 18-13291-KHK 

 and ) Chapter 7 

 ANA MARIA ALDANA ) 

 ) 

 Debtors ) 

____________________________________) 

MOTION FOR ORDER EXTENDING THE TIME TO 

FILE A COMPLAINT TO DETERMINE 

DISCHARGEABILITY OF DEBT PURSUANT TO 11 U.S.C. §523(c) 

WizdomBridge, LLC, an unsecured creditor herein, by and through the 

undersigned counsel, pursuant to Fed. R. Bankr. P. 4007(c) and 9006(b)(3), respectfully 

requests an order extending for ninety (90) days the time within which WizdomBridge, 

LLC may file a complaint to determine the dischargeability of debt under 11 U.S.C. 

§523(c), and in support thereof states as follows: 

 WizdomBridge, LLC is a party which loaned money to a Debtor-owned entity 

known as Artifact, LLC, a home builder. 

The obligation to the Movant by Artifact, LLC is unconditionally guaranteed by the 

Debtor, Pedro Felipe Valdes, under the terms of a Promissory Note dated August 8, 2018. 

 On September 28, 2018 (the “Petition Date”), the Debtors filed a voluntary petition 

for relief under Chapter 7 of the United States Bankruptcy Code, 11 U.S.C. §101 et seq. 

(the “Bankruptcy Code”), thereby commencing the above-captioned case. Originally, 

Janet M. Meiburger, Esquire was appointed as Chapter 7 Trustee in the case, but she 

resigned from the case and Kevin R. McCarthy, Esquire was appointed in her stead. 

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 The first meeting of creditors was originally set for November 7, 2018. Once Ms. 

Meiburger resigned and Mr. McCarthy was substituted as Trustee, the Section 341 first 

meeting of creditors was re-set to November 21, 2018. Mr. McCarthy ran late with his 

Section 341 docket on November 21, 2018; by the time the Valdes case was called, Mr. 

Kevin M. O’Donnell, Debtors’ counsel, had to leave the hearing to appear in the U.S. 

Bankruptcy Court. No questions by creditors were permitted on that date. The Section 

341 meeting was adjourned to December 19, 2018 for a time certain (1:00 p.m.). The 

Notice of Chapter 7 Bankruptcy Case (Official Form 309A) issued in this case on 

October 3, 2018 (Docket Entry No. 55), states that the deadline to file a complaint to 

determine the dischargeability of certain debts expires on January 6, 2018 (the 

“Dischargeability Deadline”), which was sixty (60) days after the date first set for the 

meeting of creditors in this case. 

 WizdomBridge, LLC is filing this motion seeking to extend the Dischargeability 

Deadline for a reasonable period of time in order to investigate and review certain 

discrepancies arising from the Debtors’ testimony on December 19, 2018, and the 

financial information reflected in the Schedules and/or previously provided to the 

Movant, so as to ascertain whether fraud exists in the Debtors dealings with the Movant. 

 The first time creditors had the opportunity for Debtors to testify was December 19, 

2018, and counsel has filed this Motion as quickly as reasonably practical to seek an 

extension of the Dischargeability Deadline in this case. There has not been time or 

opportunity to file a Motion for a Rule 2004 examination. 

 Fed. R. Bankr. P. 4007(c) specifies the time frame within which a complaint to 

determine dischargeability of debt must be filed. Fed. R. Bankr. P. 4007(c) provides that 

“on motion of any party in interest, after hearing on notice, the court may for cause 

extend the time to file fixed [for filing a complaint to determine the dischargeability of 

debt].” The Rule also requires that any such extension motion “shall be filed before the 

time has expired.” Fed. R. Bankr. P. 4007(b). See also, Fed. R. Bankr. P. 9006(b)(3) 

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(“The court may enlarge the time for taking action under Rule[s] ... 4007(a) ..., only to 

the extent and under the conditions stated in those rules.”). As of today, two (2) days 

after the Debtors first testified under oath at the re-scheduled (twice) meeting of creditors, 

there are only sixteen (16) days remaining until the deadline (January 6, 2019). 

 Cause exists in this case to extend the Dischargeability Deadline. An extension of 

approximately ninety (90) days from the entry of any extension order should allow 

Movant to determine whether financial information that it received from the Debtor(s) 

was falsified or misleading. Movant reserves the right to seek further extensions to the 

extent that any initial extension is insufficient to afford the time necessary to accomplish 

its investigation. 

 WHEREFORE, for the foregoing reasons, Movant respectfully requests that this 

Court enter an order (a) extending the Dischargeability Deadline for a period of ninety 

(90) days as to WizdomBridge, LLC, and (b) provide such other and further relief as the 

Court deems just and proper.

Date: December 21, 2018 

 Respectfully submitted, 

 WIZDOMBRIDGE, LLC 

 By Counsel 

/S/ Madeline A. Trainor 

Madeline A. Trainor, Esquire, (VSB #18531) 

Redmon Peyton & Braswell, LLP 

510 King Street, Suite 301 

Alexandria, VA 22314 

(703) 684-2000 

Fax 703-684-5109 

mtrainor@rpb-law.com 

Counsel for WizdomBridge, LLC 

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CERTIFICATE OF SERVICE 

I hereby certify that a true and correct copy of the foregoing Motion was served 

electronically through the ECF filing system this 21st day of December, 2018 to all 

required parties, including Counsel for the Debtors, Kevin M. O’Donnell, and the Office 

of the United States Trustee, and 

by first class mail to the following persons: 

Pedro Felipe Valdes 

Ana Maria Alana 

14531 Old Mill Road 

Centreville, VA 20121 

Debtors 

 /S/ Madeline A. Trainor 

 __________________________________________ 

 Madeline A. Trainor 

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