UNITED STATES BANKRUPTCY COURT

EASTERN DISTRICT OF VIRGINIA

Alexandria Division

)

In re: )

Traphine Freeman-Zarsah, ) Case No: 20−12181−KHK

 ) Chapter 13

Debtor. )

_________________________________ )

MOTION FOR VOLUNTARY DISMISSAL

UNDER 11 U.S.C. SEC. 1307

Debtor TRAPHINE FREEMAN-ZARSAH (the “Debtor”), by counsel, moves this Court to 

dismiss her Chapter 13 proceeding under 11 U.S.C. sec. 1307 (b). In support thereof, she states:

1. The Debtor filed a petition for relief under chapter 13 of title 11 of the United States

Code (“Bankruptcy Code”) on September 28, 2020 [doc. 1].

2. The Debtor wishes for her case to be dismissed.

3. 11 U.S.C. sec. 1307(b) provides, “On request of the debtor at any time, if the case has 

not been converted under section 706, 1112, or 1208 of this title, the court shall dismiss a

case under this chapter.”

WHEREFORE, the Debtor requests this Court to enter an order:

1. Dismissing this chapter 13 proceeding; and

2. To order any other just and equitable relief as appropriate.

TRAPHINE FREEMAN-ZARSAH

BY COUNSEL

/s/ Martin C. Conway

Martin C. Conway (VSB No. 34334)

Conway Law Group, PC

12934 Harbor Drive, Suite 107

Woodbridge, VA 22192

855-848-3011

571-285-3334 (facsimile)

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CERTIFICATE OF SERVICE

I hereby certify that a copy of the foregoing was mailed, postage-prepaid, and filed 

electronically via CM/ECF on March 17, 2021 to the creditors and parties in interest on the filed 

service list.

Traphine Freeman-Zarsah 

16748 Flotilla Way

Woodbridge, VA 22191

Debtor

Thomas P. Gorman

300 N Washington St, Ste 400

Alexandria, VA 22314

Chapter 13 Trustee

/s/ Martin C. Conway

Martin C. Conway

Case 20-12181-KHK Doc 22 Filed 03/17/21 Entered 03/17/21 16:14:18 Desc Main

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UNITED STATES BANKRUPTCY COURT

EASTERN DISTRICT OF VIRGINIA

Alexandria Division

)

In re: )

Traphine Freeman-Zarsah, ) Case No: 20−12181−KHK

 ) Chapter 13

Debtor. )

_________________________________ )

NOTICE OF MOTION

Traphine Freeman-Zarsah has filed with the court a Motion to Dismiss.

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 wish 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 March 25, 2021 you or your attorney 

must:

 Send to the parties listed below at least 14 days written notice of a hearing, which may be 

set on any regularly-scheduled motion day of the judge assigned to the case. If necessary, 

you may obtain a list of such dates by telephone from the clerk’s office. The original and 

one copy of the notice must be filed with the clerk, accompanied by a motion day cover 

sheet, a copy of which may be obtained from the clerk. If you are not represented by an 

attorney, you may instead file with the clerk a written request for hearing. If you mail 

your request for hearing to the court for filing, you must mail it early enough so the court 

will receive it on or before the date stated above. The address of the clerk’s office is as 

follows:

Clerk of Court

United States Bankruptcy Court

701 E. Broad Street

Richmond, VA 23219

You will be notified by the clerk of the hearing date and will be responsible for sending 

notice of hearing to the parties listed below.

 File with the court, at the address shown above, a written response with supporting 

memorandum as required by Local Bankruptcy Rule 9013-1(H). Unless a written

response and supporting memorandum are filed and served by the date specified, 

the Court may deem any opposition waived, treat the motion as conceded, and issue 

an order granting the requested relief without further notice or hearing. If you mail 

your response to the court for filing, you must mail it early enough so the court will 

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

listed below.

A copy of any written response must be mailed to the following persons:

Office of The United States Trustee

115 South Union Street, Plaza Level Suite 210

Alexandria, VA 22314

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 or objection and may enter an order granting that relief.

Date: March 17, 2021 /s/ Martin C. Conway

Martin C. Conway (VSB No. 34334)

Conway Law Group, PC

12934 Harbor Drive, Suite 107

Woodbridge, VA 22192

855-848-3011

571-285-3334 (facsimile)

martin@conwaylegal.com

Counsel for the Debtors

CERTIFICATE OF SERVICE

I hereby certify that a copy of the foregoing filed electronically via CM/ECF on March 

17, 2021 and mailed via first-class mail to the following parties:

Traphine Freeman-Zarsah 

16748 Flotilla Way

Woodbridge, VA 22191

Debtor

Thomas P. Gorman

300 N Washington St, Ste 400

Alexandria, VA 22314

Chapter 13 Trustee

/s/ Martin C. Conway

Martin C. Conway

Case 20-12181-KHK Doc 22 Filed 03/17/21 Entered 03/17/21 16:14:18 Desc Main

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