UNITED STATES BANKRUPTCY COURT

EASTERN DISTRICT OF VIRGINIA

Norfolk Division

IN RE: TRENTON O’NEAL DANIEL Case No. 18-70819-SCS

PAMELA SUZETTE DANIEL

Debtors. Chapter 13

NOTICE OF MOTION 

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.)

If you do not want the court to grant the relief sought in the motion, or if you want 

the court to consider your views on the motion, then, on or before fourteen (14) days 

from the date of this notice, you or your attorney must:

_x_ File with the Court, at the address shown below, a written request for a 

hearing (or a written response pursuant Local Bankruptcy Rule 9013-1 (H)). If you mail 

your request for a hearing (or 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.

Clerk of Court

United States Bankruptcy Court

600 Granby Street

Norfolk, VA 23510

You must also mail a copy to:

Timothy R. Douglass, Esq.

John W. Lee, P.C. 

291 Independence Blvd., Ste 530

Virginia Beach, VA 23462

___ Attend a hearing to be scheduled at a later date. You will receive separate 

notice of hearing. If no timely response has been filed opposing the relief requested the 

court may grant the relief without holding a hearing. 

Case 18-70819-SCS Doc 32 Filed 10/31/18 Entered 10/31/18 07:31:34 Desc Main

 Document Page 1 of 4
____Attend the hearing scheduled on the Motion (or objection) to be held on 

_______________ at _______ a.m./ p.m. at the United States Bankruptcy Court 

___________________________________________________________________.

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 or objection and enter an order granting that 

relief. 

Counsel For:

TRENTON O’NEAL DANIEL

PAMELA SUZETTE DANIEL

_10/31/2018 _/s/ Timothy R. Douglass___

Date Timothy R. Douglass, Esq.

VSB 72901

John W. Lee, P.C. 

291 Independence Blvd., Ste. 530

Virginia Beach, VA 23462

757-961-8553

Fax: 757-961-3488

Counsel for the Debtor

Certificate of Service

I hereby certify that I mailed a true and accurate copy of the foregoing to the 

Trustee, the US Trustee, the debtor, and all creditors listed on the attached List of 

Service, pursuant to Rule 7004 of the Federal Rules of Bankruptcy procedure, on this 31st

day of October 2018. 

__/s/ Timothy R. Douglass__

Timothy R. Douglass, Esq.

Case 18-70819-SCS Doc 32 Filed 10/31/18 Entered 10/31/18 07:31:34 Desc Main

 Document Page 2 of 4
UNITED STATES BANKRUPTCY COURT

EASTERN DISTRICT OF VIRGINIA

Norfolk Division

IN RE: TRENTON O’NEAL DANIEL Case No. 18-70819-SCS

PAMELA SUZETTE DANIEL

Debtor. Chapter 13

MOTION TO DISMISS CHAPTER 13 CASE BY DEBTORS

COME NOW the Debtors, Trenton O’Neal Daniel and Pamela Suzette Daniel, 

and hereby move to voluntarily dismiss their Chapter 13 Case without prejudice pursuant 

to Section 1307 (b) on the following grounds:

1. That on March 12, 2018, the debtors filed a petition under Chapter 13 in the 

Eastern District of Virginia, Norfolk Division.

2. That on April 20, 2018, the debtors filed an Amended Chapter 13 Plan that was 

confirmed by the Court on June 12, 2018. 

3. That the debtors no longer wish to proceed with their Chapter 13 Bankruptcy 

Case and they wish for their case to be dismissed. 

Timothy R. Douglass, Esquire (VSB 72901)

John W. Lee, PC 

291 Independence Blvd., Ste 530

Virginia Beach, VA 23462

Tele: 757-961-8553

Fax 757-961-3488

Attorney for Debtor

Case 18-70819-SCS Doc 32 Filed 10/31/18 Entered 10/31/18 07:31:34 Desc Main

 Document Page 3 of 4
WHEREFORE, pursuant to Section 1307 (b), the debtors move for a Voluntary 

Dismissal of their Chapter 13 Case, without prejudice and for such other and further 

relief as this Court may deem proper.

TRENTON O’NEAL DANIEL

PAMELA SUZETTE DANIEL

_/s/ Timothy R. Douglass____

Timothy R. Douglass, Esq.

VSB 72901

John W. Lee, P.C. 

291 Independence Blvd., Ste. 530

Virginia Beach, VA 23462

757-961-8553

Fax: 757-961-3488

Counsel for the Debtor

Certificate of Service

I hereby certify that I mailed a true and accurate copy of the foregoing to the 

Chapter 13 Trustee, U.S. Trustee, the debtor, and all creditors listed on the attached List 

of Service on this 31st day of October 2018.

___/s/ Timothy R. Douglass___

Timothy R. Douglass, Esq

Case 18-70819-SCS Doc 32 Filed 10/31/18 Entered 10/31/18 07:31:34 Desc Main

 Document Page 4 of 4