IN THE UNITED STATE BANKRUPTCY COURT

FOR THE EASTERN DISTRICT OF VIRGINIA

RICHMOND DIVISION

IN RE: Michael Robert Dickinson Case No. 18-34024-KRH

Debtor Chapter 13

Samuel J.T. Moore III

Plaintiff

vs.

Michael Robert Dickinson 

Debtor

and 

Carl M. Bates, Esq.

Chapter 13 Trustee

RESPONSE TO MOTION FOR 2004 EXAMINATION AND PRODUCTION OF 

DOCUMENTS

COMES NOW the Debtor Michael Robert Dickinson, by counsel, Sharon C. Stuart, 

Esquire, and as and for Debtor’s Response to the Plaintiff’s Motion for 2004 Examination filed 

on October 1, 2018 says as follows:

1. Debtor objects to plaintiff’s Motion for a 2004 Examination and Production of 

Documents from Knowledgeable Parties on the grounds that the 2004 examination’s 

scope is too broad and vague. For instance, the plaintiff’s request to produce all 

pertinent documents of the debtor three prior years from the filing of this motion as 

well as older activity and documents is akin to a fishing expedition and too vague and 

broad.

Sharon Stuart, VSB # 45026

Counsel for Debtor

Stuart Law Firm, LLC, 

2222 Monument Avenue

Richmond, VA 23220

Phone: (804) 221-2162/Fax: (804) 381-5026

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2. On October 15, 2018, the Chapter 13 Trustee filed an objection to the confirmation of 

debtor’s chapter 13 plan. Accordingly, an amendment to debtor’s schedules and 

statement were filed on October 22, 2018. In addition, bank statements from the past 

three (3) years were submitted to the trustee to examine.

3. On October 31, 2018, the Debtor filed an objection to Samuel J.T. Moore, III’s proof 

of claim number 2 (2-1 and 2-2).

4. As such, Debtor requests that the federal civil discovery rules, including but not 

limited to Bankruptcy Rules 9014, 7026 and 7028-7037, be made applicable to the 

plaintiff’s request for a 2004 Examination and production of documents.

5. Debtor requests the court order plaintiff to submit written interrogatories, and to limit 

the interrogatories to 25 questions.

6. Debtor respectfully asks this court to allow the 2004 Examination to be conducted in 

a conference room in the U.S. Bankruptcy Court. Debtor is fearful of the plaintiff and 

requests this court to provide a safe environment for the 2004 examination to take 

place. 

WHEREFORE, DEBTOR respectfully moves the Court to order:

a. that the Plaintiff send written interrogatories, limited to 25 questions, prior to the 2004 

examination of debtor;

b. that he 2004 examination take place in a conference room in the U.S. Bankruptcy Court;

and,

c. that Debtor be granted all other relief as this Court deems just and proper.

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Respectfully submitted,

Michael Robert Dickinson

By: /s/ Sharon C. Stuart

Sharon Stuart, VSB # 45026

Counsel for Debtor

Stuart Law Firm, LLC, 

2222 Monument Avenue

Richmond, VA 23220

Phone: (804) 221-2162

Fax: (804) 381-5026

Certificate of Service

I certify that on October 31 , 2018, I sent a true copy of the foregoing Answer by ECF 

transmittal, first class mail, postage prepaid, via email or fax to the following parties:

US Trustee

By Email to: USTPRegion04.RH.ECF@usdoj.gov

Samuel J.T. Moore III

Pro Se Creditor

1011 West Grace Street

Richmond, VA 23220

By First Class Mail

Carl M. Bates

By ECF Transmission

Michael Dickinson

3717 Patterson Avenue

Richmond, VA 23221

By First Class Mail

By:/s/ Sharon C. Stuart

Counsel for Debtor

Case 18-34024-KRH Doc 27 Filed 10/31/18 Entered 10/31/18 11:51:35 Desc Main

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