Robert B. Van Arsdale, AUST (Va. Bar No. 17483)

Shannon Pecoraro, Esq. (Va. Bar No. 46864)

Office of the United States Trustee

701 East Broad Street - Suite 4304

Richmond, VA 23219

Telephone (804) 771-2310

Facsimile (804) 771-2330

UNITED STATES BANKRUPTCY COURT

EASTERN DISTRICT OF VIRGINIA

RICHMOND DIVISION

In re

Shridhar V. Bhat

6331 River Road

Henrico, VA 23229

SSN/ITIN: xxx-xx-7431,

Debtor(s).

 Case No. 19-31691-KLP

Chapter 7

NOTICE OF MOTION TO EXTEND TIME 

(1) TO OBJECT TO DISCHARGE AND (2) TO FILE A

MOTION TO DISMISS PURSUANT TO 11 U.S.C. § 707 

PLEASE TAKE NOTICE THAT the United States Trustee has filed with the Court a 

Motion To Extend Time (1) To Object To Discharge And (2) To File A Motion To Dismiss 

Pursuant To 11 U.S.C. § 707 (the “Motion”) in the above-captioned case.

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 July 22, 2019, you or your 

attorney must:

( X ) File with the Court, at the address below, a written request for a hearing 

[or a written response pursuant to Local Bankruptcy Rule 9013-1(H)]. You must 

mail or otherwise file it early enough so the Court will receive it on or before the 

date stated above.

Clerk of Court

United States Bankruptcy Court

701 East Broad Street – Suite 4000

Richmond, Virginia 23219

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You must also mail a copy to:

Shannon Pecoraro, Esq.

Office of the United States Trustee

701 East Broad Street - Suite 4304

Richmond, VA 23219

( X ) Attend a hearing, which may be scheduled at a later date. You will receive a 

separate notice of hearing.

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 the relief requested.

 JOHN P. FITZGERALD, III Acting United States Trustee Region Four

Date: July 8, 2019

 /s/ Shannon Pecoraro Shannon Pecoraro, Esq.

Office of the United States Trustee

701 East Broad Street - Suite 4304

Richmond, VA 23219

July 8, 2019Telephone (804) 771-2310

Facsimile (804) 771-2330

CERTIFICATE OF SERVICE

I hereby certify that on July 8, 2019, a true copy of the foregoing was served via 

electronic mail pursuant to the Administrative Procedures of the CM/ECF System for the United 

States Bankruptcy Court for the Eastern District of Virginia to all necessary parties. In addition, 

a copy was mailed to the following:

Shridhar V. Bhat

6331 River Road

Henrico, VA 23229

/s/ Shannon Pecoraro Shannon Pecoraro

Trial Attorney

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Robert B. Van Arsdale, Esq., AUST (Va. Bar No. 17483)

Shannon Pecoraro, Esq. (Va. Bar No. 46864)

Office of the United States Trustee

701 East Broad Street - Suite 4304

Richmond, VA 23219

Telephone (804) 771-2310

Facsimile (804) 771-2330

UNITED STATES BANKRUPTCY COURT

EASTERN DISTRICT OF VIRGINIA

RICHMOND DIVISION

In re

Shridhar V. Bhat,

Debtor(s).

 Case No. 19-31691-KLP

Chapter 7

 MOTION TO EXTEND TIME TO (1) OBJECT TO DISCHARGE AND

(2) TO FILE A MOTION TO DISMISS PURSUANT TO 11 U.S.C. § 707 

COMES NOW JOHN P. FITZGERALD, III, the Acting United States Trustee for the 

Eastern District of Virginia (the "U.S. Trustee"), through the undersigned counsel and pursuant to 

§§ 707 and 727 of 11 U.S.C. §§ 101, et seq. (the “Bankruptcy Code”) and Bankruptcy Rules 

1017(e)(1), 4004, 4007 and 9006(b) of the Federal Rules of Bankruptcy Procedure, hereby 

requests this Court to extend the time to object to the above-captioned Debtor’s (the “Debtor”) 

discharge and to extend time to file a motion to dismiss this case. In support of this request, the 

U.S. Trustee states as follows:

1. This is a core proceeding concerning the administration of this estate pursuant to 

28 U.S.C. §157(b)(2)(A) and 28 U.S.C. § 1334.

2. On or about March 29, 2019, the Debtor filed a voluntary petition for relief under 

Chapter 7 of the Bankruptcy Code.

3. Harry Shaia, Jr. (the “Chapter 7 Trustee”) was appointed trustee and continues to 

serve as trustee in this bankruptcy case.

4. The U.S. Trustee is in the process of preparing a request for documentation.

5. The Chapter 7 Trustee has employed counsel.

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6. The Chapter 7 Trustee declared this case to be an asset case.

7. The adjourned § 341 meeting is scheduled for July 8, 2019, which is the same day

as the expiration of the current deadlines under §§ 707(b) and 727. The § 341 meeting is being 

further adjourned to August 5, 2019.

8. Based upon the above, the U.S. Trustee requests an extension of time to file a 

motion to dismiss this case pursuant to Bankruptcy Code § 707 and/or to object to the Debtor’s 

discharge pursuant to Bankruptcy Code § 727.

9. In the Schedules of Assets and Liabilities (the “Schedules”), the Debtor lists total 

unsecured debt of $4,093,148.00.

10. On Schedule I, the Debtor lists total gross montly income of $17,696.83 and 

Combined Average Monthly Income of $11,196.83.

11. The circumstances set forth above constitute sufficient cause for granting the 

requested extension of time.

12. There have been no previous extensions of time filed in this case and the deadline 

expires July 8, 2019.

WHEREFORE, the U.S. Trustee requests this Court to extend the date to file a motion 

to dismiss pursuant to Bankruptcy Code § 707 and/or to object to the Debtor’s discharge pursuant 

to Bankruptcy Code § 727 through and including, October 7, 2019, and for such other relief as 

this Court deems just.

Respectfully requested

JOHN P. FITZGERALD, III

Acting United States Trustee

Region Four

 By: /s/ Shannon Pecoraro Shannon Pecoraro

Trial Attorney

Date: July 8, 2019

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CERTIFICATE OF SERVICE

I do hereby certify that on July 8, 2019, a true copy of the foregoing was served via 

electronic mail pursuant to the Administrative Procedures of the CM/ECF System for the United 

States Bankruptcy Court for the Eastern District of Virginia to all necessary parties. In addition, 

a copy was mailed to the following:

Shridhar V. Bhat

6331 River Road

Henrico, VA 23229

/s/ Shannon Pecoraro Shannon Pecoraro, Esq. Trial Attorney

Office of the United States Trustee

701 East Broad Street - Suite 4304

Richmond, VA 23219

Telephone (804) 771-2310

Facsimile (804) 771-2330

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Robert B. Van Arsdale, Esq., AUST (Va. Bar No. 17483)

Shannon Pecoraro, Esq. (Va. Bar No. 46864)

Office of the United States Trustee

701 East Broad Street - Suite 4304

Richmond, VA 23219

Telephone (804) 771-2310

Facsimile (804) 771-2330

UNITED STATES BANKRUPTCY COURT

EASTERN DISTRICT OF VIRGINIA

RICHMOND DIVISION

In re

Shridhar V. Bhat,

Debtor(s).

 Case No. 19-31691-KLP

Chapter 7

ORDER EXTENDING TIME (1) TO FILE A COMPLAINT

TO OBJECT TO THE DISCHARGE AND (2) TO FILE A

MOTION TO DISMISS PURSUANT TO 11 U.S.C. § 707

This matter came before the Court upon the United States Trustee’s Motion To Extend 

Time (1) To Object To Discharge And (2) To File A Motion To Dismiss Pursuant To 11 U.S.C.

§707 (the “Motion”), and it appearing that due notice was given and that good cause exists to 

grant the relief sought in the Motion, it is hereby ORDERED:

1. The Motion is GRANTED.

2. Capitalized terms not otherwise defined herein shall have the meanings given to 

them in the Motion.

3. The last day to file a complaint to object to the above captioned Debtor’s

discharge or to file a motion to dismiss this case is extended through and including October 7, 

2019.

4. Upon entry, the Clerk is directed to send a copy of this Order to all parties on the 

service list attached hereto. 

Dated:

_________________________

Keith L. Phillips

Bankruptcy Judge

United States Bankruptcy Court

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I ask for this:

/s/ Shannon Pecoraro Shannon Pecoraro, Esq.

Office of the United States Trustee

701 East Broad Street - Suite 4304

Richmond, VA 23219 

CERTIFICATION

I hereby certify that this Order has been either served on or endorsed by all necessary 

parties.

 /s/ Shannon Pecoraro Shannon Pecoraro

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SERVICE LIST

Shridhar V. Bhat

6331 River Road

Henrico, VA 23229

David G. Browne, Esq.

Spiro & Browne, PLC

6802 Paragon Place

Suite 410

Richmond, VA 23230

Harry Shaia, Jr., Esq.

Spinella, Owings & Shaia, P.C.

8550 Mayland Drive, Suite 208

Richmond, VA 23294-4754

Shannon Pecoraro, Esq.

Trial Attorney

Office of the United States Trustee

701 East Broad Street - Suite 4304

Richmond, VA 23219 

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