UNITED STATES BANKRUPTCY COURT

EASTERN DISTRICT OF VIRGINIA

Alexandria Division

In re: 

Bluepoint Medical Associates, LLC Case No. 19-13121-KHK

Chapter 11

 Debtor

 

MOTION TO EXPEDITE HEARING

Wisteria 12810, LLC, by counsel, has filed a Motion for Relief from the Automatic Stay. 

For the reasons stated in the Motion, and due to the fact that the Movant is not adequately protected,

that the damages to the Movant are ongoing and that there is an urgent health issue, the Movant

respectfully requests an expedited hearing to be held on November 12, 2019 at 11:00 a.m. in Judge 

Kindred’s Courtroom, U.S. Bankruptcy Court, Courtroom III, 200 South Washington Street, 

Alexandria, VA. 

WISTERIA 12810, LLC

By Counsel

Dated: October 24, 2019

NEW DAY LEGAL, PLLC 

By: /s/ John C. Morgan

John C. Morgan, Esquire, VSB # 30148

Scott W. Carpenter, Esquire, VSB # 89057 

Suad Bektic, Esquire, VSB # 90012

98 Alexandria Pike, Suite 10

Warrenton, Virginia 20186

Phone: (540) 349-3232

Facsimile: (888) 612-0943

Counsel for Wisteria 12810, LLC

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CERTIFICATE OF SERVICE

I hereby certify that on this 24

th day of October 2019, I have provided a copy of the 

foregoing Motion to Expedite Hearing via the CM/ECF system or by first-class, postage paid mail, 

to the following:

Office of the United States Trustee

1725 Duke Street, Suite 650

Alexandria, VA 22314

John T. Donelan, Esquire

125 South Royal Street

Alexandria, VA 22314

Counsel for the Debtor

/s/ John C. Morgan

 John C. Morgan

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UNITED STATES BANKRUPTCY COURT

EASTERN DISTRICT OF VIRGINIA

Alexandria Division

In re: 

Bluepoint Medical Associates, LLC Case No. 19-13121-KHK

Chapter 11

 Debtor

 

CERTIFICATION FOR EXPEDITED HEARING

Wisteria 12810, LLC, by its undersigned counsel, has filed a Motion for Relief from the 

Automatic Stay. In support thereof, as required by Local Rule 9013-1(N), John C. Morgan, as 

counsel for the Movant, hereby certifies the following:

1. I am a member of the Bar of this Court;

2. I have carefully examined the matter and have concluded that there is a true necessity 

for an emergency hearing;

3. The necessity for this emergency has not been caused by any lack of due diligence; and

4. Based upon the nature of this matter and the relief requested in the Motion to Expedite 

Hearing, no bona fide effort to resolve the matter without a hearing is possible.

By: /s/ John C. Morgan

John C. Morgan, Esq. VSB # 30148

Scott W. Carpenter, Esq. VSB # 89057

Suad Bektic, Esq. VSB # 90012

New Day Legal, PLLC

98 Alexandria Pike, Suite 10

Warrenton, Virginia 20186

Phone: (540) 349-3232

Facsimile: (888) 612-0943

Counsel for Wisteria 12810, LLC

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CERTIFICATE OF SERVICE

Pursuant to Local Bankruptcy Rule 9013-1, I hereby certify that on October 24, 2019, I have 

transmitted a true copy of the foregoing Motion to Expedite Hearing and Certification for 

Expedited Hearing electronically through the Court’s CM/ECF system or by first-class, postage 

paid mail, to the following:

Office of the United States Trustee

1725 Duke Street, Suite 650

Alexandria, VA 22314

John T. Donelan, Esquire

125 South Royal Street

Alexandria, VA 22314

Counsel for the Debtor

/s/ John C. Morgan

 John C. Morgan

Case 19-13121-KHK Doc 39 Filed 10/24/19 Entered 10/24/19 21:42:18 Desc Main

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