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UNITED STATES BANKRUPTCY 

COURT SOUTHERN DISTRICT OF 

FLORIDA www.flsb.uscourts.gov

In re: Case No: 19-17564-JKO

Sylvia Lee-Jackson

 Chapter 13

Debtor /

MOTION TO RECONSIDER ORDER DENYING MOTION TO 

REOPEN CLOSED CASE AND MOTION TO VACATE ORDER OF 

DISMISSAL AND REINSTATE CHAPTER 13 FILING AND 

CERTIFICATE OF COMPLAINCE WITH LOCAL RULE 9013-1(E)

Debtor, Sylvia Lee-Jackson, by and through undersigned counsel, hereby 

moves the court to Reconsider and re-open this matter and to further vacate the Order 

Dismissing Case dated November 13, 2019 and reinstate the debtor’s Chapter 13 

Bankruptcy and states:

1. This Chapter 13 matter was filed on June 6

th 2019.

2. The debtor had filed a 4th Amended Chapter 13 Plan prior to dismissal of this 

matter for non-payment of the November payment due under the Third Amended Plan. On 

November 13, 2019 the Order granting Trustee's Request for Order Dismissing Case Upon 

Denial of Confirmation of Plan was filed.

3. The failure to file the requested $1,481.56 was a result of financial hardship 

that occurred as a result an injury requiring the debtor to incur unexpected medical 

expenses and two (2) weeks off from her employment without full compensation. 

4. A Motion to Reinstate Case was filed on 11/23/2019 (D/E 49) and the hearing 

took place on 1/6/2020 (D/E 50).

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5. During the discussion with the Trustee she asked whether undersigned 

counsel had the total amount of $10,356.08, to which he replied that he only had $4,440.00. 

6. Currently there is $5,916.08 in Trustee Weiner’s account and $4,440.00 in 

undersigned counsel’s trust account which is the total of $10,356.08 that the Trustee stated. 

Due to inadvertence or mistake it was not understood that the $10,356.08 included the 

amount already on hand with the Trustee. Therefore, the total required funds were 

available at the hearing date and the Motion to Reinstate may have been granted. 

7. Pursuant to Local Rule 9013-1(E), undersigned counsel hereby certifies that 

the debtor has tendered to undersigned counsel all funds required to be paid under the 

debtor’s plan to bring the plan current as of the date of this Motion and that said funds are 

in undersigned counsel’s trust account.

8. This motion is brought in good faith and not for purposes of delay. 

WHEREFORE, the Debtor requests Reconsider and re-open this matter and to 

further vacate the Order Dismissing Case dated November 13, 2019 and reinstate the 

debtor’s Chapter 13 Bankruptcy.

CERTIFICATION

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

for the Southern District of Florida and am in compliance with the additional 

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

By: /s/ MARTIN L. HANNAN

Martin L. Hannan

FBN: 449415

MARTIN HANNAN, P.A.

9370 S.W. 72nd St., Suite A-266

Miami, FL 33173

Tel #: 786-501-8838 Fax #: 786-322-5451

Email: info@martinhannanpa.com

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CERTIFICATE OF SERVICE

 19-17564-JKO

I HEREBY CERTIFY that on this 10th day of January, 2020, a true and correct 

copy of the foregoing ORDER DENYING MOTION TO REOPEN CLOSED CASE 

AND MOTION TO VACATE ORDER OF DISMISSAL AND REINSTATE CHAPTER 

13 FILING was served electronically with the Clerk of the Court by using the CM/ECF 

where available to all parties who are currently on the list to receive notice/ service for 

this case.

By: /s/ MARTIN L. HANNAN

Martin L. Hannan

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