UNITED STATES BANKRUPTCY COURT

EASTERN DISTRICT OF VIRGINIA

RICHMOND DIVISION

In Re: Kandise Nadine Lucas CASE NO. 20-33177-KRH

Chapter 13

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AKA: Kandise Thomas-Humphrey

DBA: Advocates For Equity In Schools

514 East Williamsburg Road

Sandston, VA 23150

Debtor Address(es):

Last four digits of Social Security No(s).: 2827

MOTION TO DISMISS, NOTICE OF MOTION AND NOTICE OF THE HEARING

NOW COMES the Chapter 13 Trustee and moves this Court to dismiss this case as provided 

in 11 U.S.C. 1307(c)(6) as the Debtor(s) are in default in making the payments under the plan.

Carl M. Bates, Chapter 13 Trustee, has filed papers with the court to dismiss this 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 seven (7) days before the date of the hearing, you 

or your attorney must:

Carl M. Bates

Chapter 13 Trustee

P.O. Box 1819

Richmond, VA 23218

(804)237-6800

VSBN 27815

Case 20-33177-KRH Doc 135 Filed 08/22/24 Entered 08/22/24 12:31:53 Desc Main

Document Page 1 of 3
 X File with the court, at the address shown below, a written request for a hearing [or a written 

response pursuant to Local Bankruptcy Rule 9013-1(H)]. If you mail your request for 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 below.

Clerk of Court

United States Bankruptcy Court

701 East Broad Street, Suite 4000

Richmond, VA 23219

Carl M. Bates

Chapter 13 Trustee

P.O. Box 1819

Richmond, VA 23218

(804)237-6800

VSBN 27815

Case 20-33177-KRH Doc 135 Filed 08/22/24 Entered 08/22/24 12:31:53 Desc Main

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You must also mail a copy to:

Carl M. Bates, Chapter 13 Trustee

Chapter 13 Trustee

P.O. Box 1819

Richmond, VA 23218

 _ 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.

 X Attend the hearing on the motion scheduled to be held on October 16, 2024 at 11:00 AM at 

United States Bankruptcy Court, 701 East Broad Street, Richmond, VA 23219, Room 5000.

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.

Dated: August 22, 2024 /s/ Carl M. Bates

Carl M. Bates

Chapter 13 Trustee

P.O. Box 1819

Richmond, VA 23218

VSBN 27815

Certificate of Service

I hereby certify that I have this 22nd day of August, 2024, by mail, hand or electronically delivered a 

true copy of the foregoing Notice of Motion and Motion to the debtor(s) Kandise Nadine Lucas, 514 

East Williamsburg Road, Sandston, VA 23150 and debtor(s) attorney, Kimberly A. Chandler, 

Esquire, via e-mail: kim@cp-lawfirm.com.

/s/ Carl M. Bates

Carl M. Bates

Chapter 13 Trustee

Carl M. Bates

Chapter 13 Trustee

P.O. Box 1819

Richmond, VA 23218

(804)237-6800

VSBN 27815

Case 20-33177-KRH Doc 135 Filed 08/22/24 Entered 08/22/24 12:31:53 Desc Main

Document Page 3 of 3