IN THE UNITED STATES BANKRUPTCY COURT

FOR THE EASTERN DISTRICT OF VIRGINIA

ALEXANDRIA DIVISION

IN RE: )

)

PATRICK ROCH, ) Case No. 19-11944-BFK

)

Debtor. ) Chapter 13

___________________________________ )

DEBTOR’S MOTION TO INCUR POST-PETITION INDEBTEDNESS

COMES NOW, Patrick Roch (the “Debtor”), by counsel, and moves this Court to

approve the purchase and financing by the Debtor of a used 2016 Volkswagen Passat 4dr Sedan.

In support of this Motion, the Debtor asserts as follows:

1. The bankruptcy case of the above Debtor is pending under Chapter 13 of the United

States Bankruptcy Code and was filed on June 12, 2019.

2. The Chapter 13 plan was confirmed on August 30, 2019.

3. The event precipitating the Debtor’s need to incur debt was an increase of the Debtor’s

weekly auto lease payment to GM financial from approximately $140.00 to

approximately $379.00.

4. The Debtor needs to replace a 2017 Chevrolet Cruze being paid directly by the debtor at

the rate of $379.00 per week.

5. The Debtor proposed to purchase a used vehicle from DriveTime in Woodbridge, VA,

who is not related to the Debtor, for the sum of $13,095, with interest at the rate of

24.201% per annum. The monthly payment will be $463.12. The Debtor will return

currently leased vehicle paid weekly at $379.00.

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6. The Debtor is current on the Chapter 13 plan payments and this purchase will not

adversely impact the Chapter 13 plan because the monthly payments for the purchased

vehicle will be significantly lower than the recently increased lease payments.

7. The Debtor believes that the purchase of this property is necessary because he generates

his income driving for Uber and Lyft and he cannot afford to continue paying the

increased lease payments while also repaying his creditors through the Chapter 13 plan.

WHEREFORE, the Debtor respectfully requests that the Court approve the purchase

described herein upon negative notice to the creditor body.

Date: September 11, 2019 Respectfully Submitted,

AP LAW GROUP, PLC

_/s/ Ashvin Pandurangi________

Ashvin Pandurangi, Bar #86966

AP Law Group, PLC

211 Park Ave.

Falls Church, VA 22046

Tel: (571) 969-6540

Counsel for Debtor

CERTIFICATE OF SERVICE

I hereby certify that on the 11th day of September, 2019, a true copy of the foregoing

Motion to Incur Post-Petition Indebtedness was served via ECF on the Chapter 13 Trustee and

first class mail, postage prepaid to the attached list of creditors.

_/s/ Ashvin Pandurangi_______

Ashvin Pandurangi, Bar #86966

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}bk1{Credito AresMatix}bk{

Affirm Inc

Affirm Incorporated

Po Box 720

San Francisco, CA 94104

Alfred, Bacon Halfhill & Young

11350 Random Hills Road

Suite 700

Fairfax, VA 22030

Amex

Correspondence/Bankruptcy

Po Box 981540

El Paso, TX 79998

Bank of America attn: BK Dept

475 Cross Point Pkwy

PO Box 9000

Getzville, NY 14068

Barclays Bank Delaware

Attn: Correspondence

Po Box 8801

Wilmington, DE 19899

Bmw Financial Services

Attn: Bankruptcy Department

Po Box 3608

Dublin, OH 43016

Capital One

P.O. Box 30285

Salt Lake City, UT 84130

Chase Card Services

Correspondence Dept

Po Box 15298

Wilmington, DE 19850

Fifth Third Bank

PO Box 630412

Cincinnati, OH 45263

GM Financial

PO Box 181145

Arlington, TX 76096

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Mirror Ridge HOA

1225 Alma Road, Ste 100

Richardson, TX 75081

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