UNITED STATES BANKRUPTCY COURT

EASTERN DISTRICT OF VIRGINIA

RICHMOND DIVISION

In Re: Christopher Edward Tate, Sr.

Amanda Renee Tate

CASE NO. 20-33403-KRH

Chapter 13

)

)

AKA: Amanda Renee Graves

419 Otey Lane

Sandston, VA 23150

Debtor Address(es):

Last four digits of Social Security No(s).: 7289

4021

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)(1) for unreasonable delay that is prejudicial to creditors due to the 

debtor(s) having failed to address claim and/or funding issues that will prevent the plan from 

paying creditors as proposed in the current confirmed 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 20-33403-KRH Doc 40 Filed 04/26/21 Entered 04/26/21 13:06:35 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 above.

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 20-33403-KRH Doc 40 Filed 04/26/21 Entered 04/26/21 13:06:35 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 June 02, 2021 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: April 26, 2021 /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 26th day of April, 2021, by mail, hand or electronically delivered 

a true copy of the foregoing Notice of Motion and Motion to the debtor(s) Christopher Edward 

Tate, Sr. and Amanda Renee Tate, 419 Otey Lane, Sandston, VA 23150 and debtor(s) 

attorney, James E. Kane, Esquire, via e-mail: jkane@kaneandpapa.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 20-33403-KRH Doc 40 Filed 04/26/21 Entered 04/26/21 13:06:35 Desc Main

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