John P. Fitzgerald, III

Acting United States Trustee

For Region 4

Jack Frankel, Attorney

Office of United States Trustee

1725 Duke Street, Suite 650

Alexandria, VA 22314

(703) 557-7229

Jack.I.Frankel@USDOJ.GOV

UNITED STATES BANKRUPTCY COURT

Eastern District of Virginia 

Alexandria Division 

In re:

3518 1st Ave., LLC

 Debtor.

Case No. 19-12026-BFK

Chapter 11

Hearing August 13, 2019, 11:00 am

 Courtroom I, 2nd Floor

 

Notice of Motion and Notice of Hearing

The Office of the U.S. Trustee has filed papers with the Court:

(1) To dismiss or convert this case to a case under Chapter 7 pursuant to Section 

1112(b)(4) of the Bankruptcy Code;

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 wish 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 seven days before the scheduled 

hearing, Tuesday, August 13, 2019, at 11:00 am, you or your attorney must:

■ File with the court, at the address shown below, a written response with 

supporting memorandum as required by Local Bankruptcy Rule 9013-1(H). 

Unless a written response and supporting memorandum are filed and served 

by the date specified, the Court may deem any opposition waived, treat the 

motion as conceded, and issue an order granting the requested relief without 

further notice or hearing. 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. You must also mail a copy to the persons listed below.

Case 19-12026-BFK Doc 12-1 Filed 07/11/19 Entered 07/11/19 13:03:24 Desc

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■ Attend the hearing scheduled to be held on Tuesday, August 13, 2019, @ 11:00 

o’clock a.m. in Courtroom No. 1, 2nd Floor, United States Bankruptcy Court, 200 

South Washington Street, Alexandria, Virginia 22314. If no timely response has 

been filed opposing the relief requested, the court may grant the relief 

without holding a hearing. 

■ A copy of any written response must be mailed to the following persons:

■ United States Trustee, Region IV

1725 Duke Street, Suite 650

Alexandria, VA 22314

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.

John P. Fitzgerald, III

Acting United States Trustee

For Region 4

/s/ Jack Frankel

Jack Frankel, Attorney

Office of United States Trustee

1725 Duke Street, Suite 650

Alexandria, VA 22314

(703) 557-7229

Certificate of Service

 I hereby certify that on the 11th day of July, 2019, I mailed, United States mail, first class, postage 

prepaid, a true copy of this motion and notice of motion and hearing to:

3518 1st Ave., LLC

2221 South Clark St. 

Arlington, VA 22202

Ashvin Pandurangi

AP Law Group, PLC 

211 Park Ave. 

Falls Church, VA 22046

/s/ Jack Frankel

Case 19-12026-BFK Doc 12-1 Filed 07/11/19 Entered 07/11/19 13:03:24 Desc

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