Seth J. Marks, Esq. (VSB# 75153)

Pagano & Marks, P.C.

25 E. Main Street

Richmond, VA 23219

(804) 447-1002

IN THE UNITED STATES BANKRUPTCY COURT

FOR THE EASTERN DISTRICT OF VIRGINIA

RICHMOND DIVISION

IN RE: STACEY G. KELLY, Case No. 20-30212-KRH

Chapter 13

Debtor. Trustee: Wade

NOTICE OF MOTION

NOTICE IS HEREBY GIVEN that a Motion to Dismiss been filed with the Court.

Attached is a copy of the Motion:

If you do not want the Court to authorize the motion, then on or before seven (7) days from the 

date of service of this motion, you or your attorney must:

File a written objection and a copy with the Court at:

United States Bankruptcy Court

701 E. Broad Street

Richmond, Virginia 23219

If you mail your objection to the Court for filing, you must mail it early enough so that the 

Court will receive it on or before the date stated above. You must also mail a copy to the 

attorney for the debtor(s) (or to the debtor(s) if the debtor(s) is not represented by counsel) and 

to the Chapter 13 Trustee:

Address of attorney for the debtor(s): Seth J. Marks, Esquire

Pagano & Marks, P.C.

25 E. Main Street

Richmond, VA 23219

Address of Chapter 13 Trustee: Suzanne E. Wade

7202 Glen Forest Drive, Suite 202

Richmond, VA 23226

Respectfully submitted,

STACEY G. KELLY

By Counsel
Seth J. Marks, Esq. (VSB# 75153)

Pagano & Marks, P.C.

25 E. Main Street

Richmond, VA 23219

(804) 447-1002

Date: December 28, 2022

/s/ Seth J. Marks, Esq. 

Seth J. Marks, Esq. (VSB# 75153)

Pagano & Marks, P.C.

25 E. Main Street

Richmond, VA 23219

(804) 447-1002
Seth J. Marks, Esq. (VSB# 75153)

Pagano & Marks, P.C.

25 E. Main Street

Richmond, VA 23219

(804) 447-1002

IN THE UNITED STATES BANKRUPTCY COURT

FOR THE EASTERN DISTRICT OF VIRGINIA

RICHMOND DIVISION

IN RE: STACEY G. KELLY, Case No. 20-30212-KRH

Chapter 13

Debtor. Trustee: Wade

MOTION TO DISMISS

COMES NOW the Debtor, by Counsel, and moves the Court to allow the voluntary 

dismissal of his case, and in support thereof, state as follows:

1. The Debtor filed her voluntary petition under Chapter 13 of the U.S. Bankruptcy 

Code on January 14, 2020. Suzanne E. Wade was appointed as the Chapter 13 

Trustee (the “Trustee”) in his case.

2. The case has not previously been converted nor is there any pending motions to 

convert the case to Chapter 7 nor any pending motions to dismiss the case with 

prejudice.

3. The Debtor no longer desires to be in Chapter 13.

4. That under 11 U.S.C. 1307(b) the Debtor is entitled to have this Chapter 13 case 

dismissed at any time, and that the Debtor, by this motion, requests that such case 

be dismissed.

WHEREFORE, the Debtor moves this Court to enter an Order dismissing his current 

Chapter 13 case.

Respectfully Submitted, 

STACEY G. KELLY

/s/ Seth J. Marks, Esq. 

Seth J. Marks, Esq. (VSB# 75153)

Pagano & Marks, P.C.

25 E. Main Street

Richmond, VA 23219

(804) 447-1002
Seth J. Marks, Esq. (VSB# 75153)

Pagano & Marks, P.C.

25 E. Main Street

Richmond, VA 23219

(804) 447-1002

CERTIFICATE OF SERVICE

I hereby certify I mailed the foregoing Motion electronically via CM/ECF to the 

Chapter 13 Trustee, and to all parties on the attached mailing matrix and to the parties 

below.

Stacey G. Kelly

4209 Seamore Street

Richmond, VA 23223

Suzanne E. Wade, Chapter 13 Trustee

7202 Glen Forest Drive, Suite 202

Richmond, VA 23226

Office of the US Trustee

701 E. Broad Street, Suite 4304

Richmond, VA 23219

/s/ Seth J. Marks, Esq.

Seth J. Marks, Esq.