Office of United States Trustee

Joseph Guzinski

Asst. United States Trustee

1725 Duke Street, Suite 650

Alexandria, VA 22314

(703) 557-7274

joseph.a.guznski@usdoj.gov

IN THE UNITED STATES BANKRUPTCY COURT

FOR THE EASTERN DISTRICT OF VIRGINIA

Alexandria Division

In re:

KATHIUSKA I. RAMIREZ,

 Debtor.

Case No.19-13447-KHK

 Chapter 7

UNITED STATES TRUSTEE'S MOTION TO EXTEND DEADLINE

FOR OBJECTIONS TO DISCHARGE OR DISCHARGEABILITY OF DEBTS

Comes Now, John P. Fitzgerald, III, Acting United States Trustee for Region Four, and, 

pursuant to Bankruptcy Rules 4004(a) and (b), hereby requests an extension of time to file a 

complaint objecting to the discharge of the debtor pursuant to 11 U.S.C. § 727 and challenge the

dischargeability of certain debts. In support of his motion the Acting United States Trustee states 

the following:

1. The Debtor commenced this proceeding by filing a petition for relief under Chapter 7 

of the Bankruptcy Code on October 21, 2019. [Docket Entry #1]

2. Along with the voluntary petition, the Debtor filed his Individual Schedule(s) and/or 

Statement(s), Lists. The Debtor signed each of the documents under penalty of perjury. [Id at 34

and 41].

3. Janet Meiburger was appointed the interim chapter 7 trustee and a 341(a) Meeting of 

Creditors (“Meeting of Creditors”) was set for and concluded on November 21, 2019. She 

remains the chapter 7 trustee. [Docket Entry #4] 

4. Pursuant to Bankruptcy Rule 4004(a), the deadline for a party wishing to object to the

Debtor’s discharge or challenge dischargeability of certain debts is (60) days from the first date

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set for the Meeting Of Creditors. The deadline in this case is January 21, 2020. [Docket entry 

#4]

5. Bankruptcy Rule 4004(b) provides that this deadline may be extended for cause upon

the request of any party in interest after hearing and notice, and prior to the expiration of the

objection period.

6. The United States Trustee requests that the deadline for any party to object to the

Debtor’s discharge or dischargeability of certain debt be extended 90 days, through and

including April 20, 2020.

7. The United States Trustee has received information regarding the veracity of the 

schedules and statements filed by the Debtor which warrants further investigation and review.

8. The United States Trustee requests additional time so that he can complete his 

investigation of the circumstances in this case, which will enable him to determine whether filing 

a complaint objecting to discharge is warranted in this case.

9. Extensions of time for objecting to discharge should be granted liberally absent a clear 

showing of bad faith on the part of the party requesting the extension. In re Kellogg, 41 B.R. 

836, 838 (Bankr. W.D. OK 1984).

10. In addition, the granting of the requested extension will not prejudice the debtor in

any way and will not impede the efficient administration of the case. In re Knobel, 54 B.R. 458,

461 (Bankr. D. Col. 1985)(extension of time to object to debtor's discharge granted where

extension requested by creditor was not made in bad faith, the delay as a result of the extension

is insubstantial and would not adversely affect the administration of the case, and the extension

would not result in any prejudice to the debtor).

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WHEREFORE, THE UNITED STATES TRUSTEE MOVES THE COURT TO: 

1. Extend the deadline for objecting to discharge of the Debtor or challenging

dischargeability of debts for 90 days, through and including April 20, 2020;

2. Grant such further relief as the Court may deem just and fair.

January 16, 2020 JOHN P. FITZGERALD, III

ACTING U.S. TRUSTEE, REGION 4

By: /s/ Joseph A. Guzinski

Joseph A. Guzinski

Asst. United States Trustee

Office of United States Trustee

1725 Duke Street, Suite 650

Alexandria, VA 22314

(703) 557-7274

joseph.a.guzinski@usdoj.gov

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CERTIFICATE OF SERVICE

I hereby certify that on January 16, 2020, I electronically filed the foregoing motion to 

extend time with the Clerk of the Court and transmitted a true and correct copy of said 

documents electronically through the electronic case filing system or by first class United States 

mail, postage prepaid to the following:

Kathiuska I. Ramirez 

11515 Hearthstone Court 

Reston, VA 20191

Debtor

Nathan A. Fisher

Fisher-Sandler, LLC 

3977 Chain Bridge Road, #2 

Fairfax, VA 22030

Email: Fbarsad@cs.com

Counsel for Debtor

Janet M. Meiburger

The Meiburger Law Firm, P.C. 

1493 Chain Bridge Road, Suite 201 

McLean, VA 22101-5726 

703-556-9404 

Email: trustee@meiburgerlaw.com

Chapter 7 Trustee

/s/ Paula Blades

Paula Blades

Paralegal Specialist

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