THE UNITED STATES BANKRUPTCY COURT

FOR THE EASTERN DISTRICT OF VIRGINIA

Richmond Division

In re:

 BOYD WAYNE THOMASSON

 Debtor

Case No. 20-30796-KRH

 Chapter 7

MOTION TO REOPEN CHAPTER 7 BANKRUPTCY CASE

COMES NOW the Debtor, Boyd Wayne Thomasson, (hereinafter “Debtor”) by counsel, 

Suad Bektic of the firm New Day Legal, PLLC, and he hereby moves this Honorable Court to 

reopen his Chapter 7 bankruptcy case. In support of his Motion, the Debtor respectfully states

the following:

JURISDICTION

1. This is a core proceeding pursuant to 28 U.S.C. §157 (b)(2).

2. Venue is proper in this District under 28 U.S.C. § 1409(a).

3. Pursuant to local rule or other order of the District Court, all bankruptcy cases and 

all proceedings that arise under Title 11 have been referred, as permitted by 28 U.S.C. § 157, to 

the United States Bankruptcy Court for the Eastern District of Virginia. 

THE DEBTOR

4. The Debtor, Boyd Wayne Thomasson, filed the subject bankruptcy case pursuant 

to Chapter 7 of the Bankruptcy Code on February 14, 2020, and Peter J. Barrett was appointed 

the Chapter 7 Trustee to administer the case.

5. The Chapter 7 Trustee’s Report of No Distribution was filed on May 13, 2020, 

and the Debtor received a discharge on July 10, 2020.

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6. The bankruptcy case was closed by the Court on July 13, 2020.

GROUNDS TO REOPEN THE BANKRUPTCY CASE

7. Mr. Thomasson has a pending class-action personal injury claim against 3M 

Company et al, pending in the U.S. District Court for the Northern District of Florida under Case 

Number 8:20-cv-19779-MCR-HTC. When the Chapter 7 case was filed, although the Debtor had 

been solicited by a nationwide advertisement to participate in the class-action suit, the Debtor did 

not reveal to Counsel or to the Trustee his interest in the claim.

8. The attorney representing Mr. Thomasson in the personal injury claim has advised 

the Debtor that Schedules B and C should be amended to reflect this claim and that doing so will 

be important to successful prosecution and resolution of the claim.

9. The Debtor seeks to reopen his Chapter 7 case in order to file amended Schedules

B and C, based on the recommendation of his personal injury attorney. 

10. Pursuant to Section 350(b) of the Bankruptcy Code, 11 U.S.C. § 350(b), a case 

may be reopened “to accord relief to the debtor.”

11. Relief can be accorded to the Debtor and cause exists in this case to reopen the 

bankruptcy case.

12. Pursuant to Rule 5010 of the Federal Rules of Bankruptcy Procedure, when the 

case is reopened pursuant to Section 350(b) of the Bankruptcy Code, a trustee shall not be 

appointed unless the court determines that a trustee is necessary to protect the interests of 

creditors and the Debtor or to insure efficient administration of the case. The Debtor does not 

believe that a trustee is necessary in the reopened case.

WHEREFORE, the Debtor prays that this Court enter an Order reopening his Chapter 7

bankruptcy case and that no trustee be appointed in the reopened case, and for such other and 

further relief deemed meet and just.

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Respectfully submitted,

BOYD WAYNE THOMASSON

By Counsel

NEW DAY LEGAL, PLLC

/s/ Suad Bektic 

Suad Bektic, Esquire, VSB # 90012

8500 Mayland Drive, 1st Floor

Henrico, VA 23294

(540) 349-3232 (tel.)

(888) 612-0943 (fax)

sbektic@newdaylegal.com

Counsel for the Debtor

CERTIFICATE OF SERVICE

I hereby certify that on 7

th day of May, 2024, a true copy of the foregoing Motion to 

Reopen Chapter 7 Bankruptcy Case was mailed, via first class postage paid, or served via the 

CM/ECF system, to all creditors and parties in interest.

/s/ Suad Bektic ______ 

 Suad Bektic

IRS

P.O. Box 7346

Philadelphia, PA 19101-0000

Commonwealth of Virginia

P.O. Box 2156

Richmond, VA 23218-0610

AAFES

Attn: Bankruptcy

P.O. Box 650060

Dallas, TX 75265-0000

AAFES

3911 Walton Walker

Dallas, TX 75266-0000

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Capital One/Helzberg

Attn: Bankruptcy

P.O. Box 30285

Salt Lake City, UT 84130-0000

Capital One/Helzberg

P.O. Box 30253

Salt Lake City, UT 84130-0000

Evansville Tchrs FCU

4401 Theatre Dr

Evansville, IN 47716-0000

Navy FCU

P.O. Box 3000

Merrifield, VA 22119-0000

USAA Federal Savings Bank

Attn: Bankruptcy

10750 McDermott Freeway

San Antonio, TX 78288-0000

USAA Federal Savings Bank

P.O. Box 47504

San Antonio, TX 78265-0000

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