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James E. Kane (VSB #30081) 

KANE & PAPA, P.C. 

1313 East Cary Street 

Richmond, VA 23219 

(804) 225-9500 (phone) 

(804) 225-9598 (fax) 

jkane@kaneandpapa.com

Counsel for Debtors 

IN THE UNITED STATES BANKRUPTCY COURT 

FOR THE EASTERN DISTRICT OF VIRGINIA 

Richmond Division 

 

IN RE: ) 

 ) 

MICHAEL WIGGINS ) Case No. 20−34740−KLP 

BERYL MUHAMMAD WIGGINS ) Chapter 7 

 ) 

 Debtors ) 

MOTION TO EXPEDITE HEARING ON MOTION 

TO EXTEND STAY AND TO SHORTEN NOTICE PERIOD 

 COME NOW the Debtors, by counsel, and move this Court to Expedite the Hearing on the 

Motion to Extend the Automatic Stay and to Shorten Notice Period, and in support thereof state as 

follows: 

1. On December 2, 2020 (hereinafter the “Petition Date”), the Debtors filed a 

petition for relief under Chapter 7 of the Bankruptcy Code (the “instant case”). 

2. Within the year prior to filing the instant case, Debtors have been debtors in one 

(1) pending Chapter 13 bankruptcy case (the “previous case”). The previous case was a Chapter 

13 bankruptcy case filed on August 3, 2018 and dismissed on or about April 15, 2020 (Case No. 

18-33969) (the “previous case”). In addition, Mr. Wiggins has been a debtor in a Chapter 7 case 

filed on October 31, 2011 wherein he received a discharge on February 8, 2012 (Case No. 11-

36912). 

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 3. Pursuant to 11 U.S.C. § 362, the hearing on the Debtors’ Motion to Extend the 

Automatic Stay (“Motion”) must be heard within thirty (30) days of the filing of the petition. 

 4. The Court does not have any available hearing dates to allow the required fourteen 

(14) days’ notice of the hearing on the Motion. 

WHEREFORE, the Debtors respectfully request that the Court expedite the hearing on 

the Motion to Extend the Automatic Stay, Shorten the Notice Period required for said Motion, and 

grant it such other and further relief as is just and proper. 

Respectfully submitted, 

MICHAEL WIGGINS 

BERYL MUHAMMAD WIGGINS 

By Counsel 

/s/ James E. Kane 

James E. Kane (VSB# 30081) 

KANE & PAPA, P.C. 

P. O. Box 508 

Richmond, Virginia 23218-0508 

Telephone (804) 225-9500 

Counsel for Debtors 

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CERTIFICATION 

 I, James E. Kane, pursuant to Local Rule 9013-1(N), do hereby certify that: 

 

 1. I have carefully examined the matter and concluded that there is a true need for 

an emergency hearing, 

 2. I have not created the emergency through any lack of due diligence. 

 3. I have made a bona fide effort to resolve the matter without hearing. 

By: /s/ James E. Kane 

 James E. Kane 

CERTIFICATE OF SERVICE 

I certify that on December 10, 2020, I have transmitted a true copy of the 

foregoing document electronically through the Court’s CM/ECF system or by mail to the 

Debtor, Chapter 7 trustee, the United States trustee if other than by the electronic means 

provided for at Local Bankruptcy Rule 2002-1, all attorneys appearing in the previous 

case as listed below, and to all creditors and parties in interest of the mailing matrix 

attached hereto. 

/s/ James E. Kane 

Counsel for Debtors 

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IN THE UNITED STATES BANKRUPTCY COURT 

FOR THE EASTERN DISTRICT OF VIRGINIA 

Richmond Division 

 

IN RE: ) 

 ) 

MICHAEL WIGGINS ) Case No. 20−34740−KLP 

BERYL MUHAMMAD WIGGINS ) Chapter 7 

 ) 

 Debtors ) 

NOTICE OF MOTION AND HEARING 

 The above Debtors have filed a Motion for an Expedited Hearing on the Motion to Extend 

the Automatic Stay and to Shorten the Notice Period in the above matter.

 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 you or your attorney must:

 File with the court, at the address shown below, a written request for a hearing [or 

written response pursuant to Local Bankruptcy Rule 9013-1(H)]. If you mail your 

request for a 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, to:

Clerk of Court

United States Bankruptcy Court

701 East Broad Street 

Richmond, VA 23219

You must also mail a copy to:

James E. Kane, Esquire

Kane & Papa, P.C. 

1313 East Cary Street 

Richmond, Virginia 23219 

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 Attend a hearing on December 22, 2020 at 10:00 a.m. in the Honorable Keith 

L. Phillips’ Courtroom, U.S. Bankruptcy Court, 701 E. Broad Street, Room 

5100, Richmond, VA 23219If no timely response has been filed opposing the 

relief requested, the court may grant the relief without holding a hearing.

 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.

Respectfully submitted, 

MICHAEL WIGGINS 

BERYL MUHAMMAD WIGGINS 

By Counsel 

/s/ James E. Kane 

James E. Kane (VSB# 30081) 

KANE & PAPA, P.C. 

P. O. Box 508 

Richmond, Virginia 23218-0508 

Telephone (804) 225-9500 

Counsel for Debtors 

CERTIFICATE OF SERVICE 

I certify that on December 10, 2020, I have transmitted a true copy of the foregoing 

document electronically through the Court’s CM/ECF system or by mail to the Debtor, Chapter 

13 trustee, the United States trustee if other than by the electronic means provided for at Local 

Bankruptcy Rule 2002-1, all attorneys appearing in the previous case as listed below, and to all 

creditors and parties in interest of the mailing matrix attached hereto. 

/s/ James E. Kane 

Counsel for Debtors 

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AES/HEAA

Attn: Bankruptcy

1200 N. 7th Street

Harrisburg, PA 17102

Bridgecrest Credit

7300 E Hampton Ave

Suite 101

Mesa, AZ 85209

Chaplin & Gonet - Mr & Ms King

5211 West Broad Street

Suite 100

Richmond, VA 23230

City of Petersburg

Treasurer's Office

P.O. Box 1271

Petersburg, VA 23804

City of Petersburg Utilities

P.O. Box 1271

Petersburg, VA 23804

Comcast Communications Llc

c/o Waypoint Resource Group

Po Box 1081

San Antonio, TX 78294

Credit Acceptance

25505 West 12 Mile Rd

Suite 3000

Southfield, MI 48034

Direct TV

PO Box 11732

Newark, NJ 07101

Dominion Energy

P O Box 26543

Colonial Heights, VA 23834

Elephant Auto Insurance

c/o Receivable Management Inc

7206 Hull Rd Ste 211

Richmond, VA 23235

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Patient First

c/o Receivable Management Inc

7206 Hull Rd Ste 211

Richmond, VA 23235

Petersburg Hospital Company LL

Southside Reg Med Ctr

324 S Main St

Emporia, VA 23847

Russel Taylor

14110 Kendal Wood Drive

Upper Marlboro, MD 20772

Shippers Choice of VA

c/o Purnell McKennett

9214 Center St, STE 101

Manassas, VA 20110

Southside Regional Medical

c/o Newsome Law Office

324 S Main St

Emporia, VA 23847

TACS

P O Box 31800

Henrico, VA 23294

Trexis One Insurance

c/o I C System Inc

P.O. Box 64378

St. Paul, MN 55164

Virginia Farm Bureau Fire & Ca

c/o Chaplin & Gonet

4808 Radford Ave.

Richmond, VA 23230

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