UNITED STATES BANKRUPTCY COURT

SOUTHERN DISTRICT OF FLORIDA

MIAMI DIVISION

In Re: Case No. 19-19495-RAM

LORINIE N. HUERTAS Chapter 13

SSN: XXX-XX-5197

 Debtor /

MOTION TO EXTEND THE DEADLINE FOR OBJECTING TO DISCHARGE

COMES NOW THE CREDITOR, WORLD O WORLD CORPORATION,

(“CREDITOR”) by and through undersigned counsel, and files this Motion to Extend the 

Deadline for Objecting to Discharge and states as follows:

1. The debtor filed a skeleton petition Chapter 7 case on July 17, 2019.

2. On August 6, 2019, the case was dismissed pursuant to 11 U.S.C. § 105(a) for failure to 

file required documents not filed with the skeleton filing [DE# 09].

3. The information filed in the bankruptcy case on August 16, 2019 at the time of the filing 

of the motion to reinstate, is deficient pursuant to §521.

4. On September 9, 2019, the Chapter 7 case was Reinstated [DE# 19].

5. The 341 Meeting of Creditors, the fourth scheduled in this case, was held and concluded 

on November 12, 2019.

6. The Debtor testified at the 341 Meeting of Creditors that she is married and resides with 

her non-filing spouse but did not include any income from the non-filing spouse on her 

schedules. This may be a factor in qualifying for a Chapter 7 or a Chapter 13.

7. Additionally, the Debtor did not include any business information on her schedule B or in 

the Statement of Financial Affairs, even though her 2018 Income Tax Return shows 

income received from a business.

8. Furthermore, the Debtor did not include page 2 of Schedule J Expenses despite Debtor’s 

counsel testifying that he would file the missing document.

9. Due to the debtor’s delay in providing information which should have been included in 

her original schedules, the Creditor, World-O-World Corp requires additional time in 

which to investigate the financial dealings of the debtor.

Case 19-19495-RAM Doc 39 Filed 11/27/19 Page 1 of 3
10. The current deadline for filing objections to the debtor’s discharge in connection with this 

case is December 2, 2019. The Creditor requests a 60-day extension of this deadline to 

February 2, 2019.

11. F.R.B.P. 9006(b) provides that the Court may, for cause shown, before expiration of the 

time originally prescribed or as extended, enter an order enlarging time. For the above 

reasons, good cause has been demonstrated.

WHEREFORE, the Creditor respectfully requests that the Court:

1. Extend the deadline for filing objections to the Debtor’s discharge to February 2, 2018

together with any other relief the Court deems appropriate under the facts.

CERTIFICATE PURSUANT TO LOCAL RULE 9011-4(b)(1)

I hereby certify that I am admitted to the Bar of the United States District Court for the 

Southern District of Florida and I am in compliance with the additional qualifications to practice 

in the court set forth in Local Rule 2090-1(A).

/s/David Tybor, Esq. 

Attorney for “CREDITOR”

Gonzalez & Tybor P.A.

9000 Sheridan St. #95

Hollywood, FL 33024

Tel: (954)378-8184

Fax: (305)873-8679

david@gtlawyers.com

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a true and correct copy of the foregoing has been sent 

electronically or via U.S. Mail to the following, this 27th day of November 2019.

Via Electronic Notice:

Ralph S. Francois, Esq. on behalf of Debtor Lorinie N Huertas

lawyerfrancois@gmail.com, lawrfrancois@yahoo.com

Office of the US Trustee

USTPRegion21.MM.ECF@usdoj.gov

Case 19-19495-RAM Doc 39 Filed 11/27/19 Page 2 of 3
Gavin N Stewart on behalf of Creditor Specialized Loan Servicing LLC

bk@stewartlegalgroup.com

Joel L Tabas

JLT@tfsmlaw.com, kborrego@tabassoloff.com;jcepero@tabassoloff.com;lshortino@tabassoloff

.com;jlt@trustesolutions.net

Joel L Tabas, Esq on behalf of Trustee Joel L Tabas

jtabas@tabassoloff.com, jcepero@tabassoloff.com;kborrego@tabassoloff.com

/s/David Tybor, Esq. 

Attorney for "CREDITOR"

Gonzalez & Tybor P.A.

9000 Sheridan St. #95

Hollywood, FL 33024

Tel: (954)378-8184

Fax: (305)873-8679

david@gtlawyers.com

Case 19-19495-RAM Doc 39 Filed 11/27/19 Page 3 of 3