UNITED STATES BANKRUPTCY COURT

FOR THE SOUTHERN DISTRICT OF FLORIDA

(MIAMI, DIVISION)

In re: : CASE NO.: 19-25083-AJC

:

ORLANDO JESUS GONZALEZ, : CHAPTER 7

:

Debtor. :

____________________________________/

MOTION TO REVOKE DISCHARGE 

IN ACCORDANCE WITH APPROVED SETTLEMENT

COMES NOW, Robert A. Angueira, Trustee in Bankruptcy (the “Trustee”), and files this 

Motion to Revoke Discharge in Accordance with Approved Settlement and states as follows:

1. The Debtor filed a voluntary petition under Chapter 7 of the Bankruptcy Code on

November 7, 2019 (the “Petition Date”).

2. Robert A. Angueira is the duly appointed Chapter 7 Trustee.

3. On July 24, 2020, this Court entered an Order Granting Trustee’s Motion to

Approve Stipulation to Compromise Controversy [D.E. 70] (the “Settlement Order”). 

4. The Settlement Order provides that the Debtor would pay the Trustee the total

sum of $6,000.00 to be paid in 20 equal monthly payments of $300.00 to be made on the 10

th day 

of each month starting on July 10, 2020 and ending on February 10, 2022. 

5. Paragraph 12 of the Settlement Order also provides as follows:

“If the Debtor fails to timely make any of the payments

described in paragraph 2, then after ten (10) days written

notice emailed or mailed to the Debtor and the Debtor’s

counsel, the Trustee would be entitled to file a Motion and

request a hearing seeking to revoke the Debtor’s bankruptcy

discharge.”

6. The Debtor has defaulted on the payment terms under the Settlement Order.

Specifically, the Debtor has failed to make the $300.00 payments that were due on June 10, 2021

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and July 10, 2021. As a result, the Debtor is $600.00 in arrears as of the date of this Motion. 

Additionally, a payment of $300.00 is due on August 10, 2021. 

7. On July 12, 2021, the Trustee mailed a default letter to the Debtor, which is 

enclosed as Exhibit A.

8. The Trustee requests that the Debtor’s discharge be revoked under the terms of 

the Settlement Order; unless $900.00 is received by the Trustee in clear funds by August 10, 

2021. 

WHEREFORE, the Trustee respectfully requests the entry of an Order (a) granting this 

motion; (b) revoking the Debtor’s discharge unless $9000.00 in clear funds is received by the 

Trustee on or before August 10, 2021; (c) granting such other and further relief as this Court 

deems appropriate.

Respectfully submitted this 29th day of July, 2021.

ROBERT A. ANGUEIRA, P.A.

16 S.W. 1st Avenue

Miami, Florida 33130

Tel. (305) 263-3328

e-mail yanay@rabankruptcy.com

By /s/ Yanay Galban

 YANAY GALBAN, ESQ

 Florida Bar No. 0105146

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CASE NO.: 19-25083-AJC

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CERTIFICATE OF SERVICE

I CERTIFY that a true and correct copy of the foregoing was served by U.S. mail on this 

29th day of July, 2021, to the Debtor as follows: 

Orlando Jesus Gonzalez

11960 SW 4th Ter 

Miami, FL 33184

I CERTIFY that a true and correct copy of the foregoing was served via the Notice of 

Electronic Filing on this 29th day of July, 2021, to:

• Robert A Angueira trustee@rabankruptcy.com, 

fl79@ecfcbis.com;raa@trustesolutions.net;tassistant@rabankruptcy.com;richard@rabank

ruptcy.com;lillian@rabankruptcy.com

• Yanay Galban yanay@rabankruptcy.com, robert@rabankruptcy.com

• Office of the US Trustee USTPRegion21.MM.ECF@usdoj.gov

• Ariel Rodriguez ariel.rodriguez@usdoj.gov

ROBERT A. ANGUEIRA, P.A.

16 S.W. 1st Avenue

Miami, Florida 33130

Tel. (305) 263-3328

e-mail yanay@rabankruptcy.com

By /s/ Yanay Galban

 YANAY GALBAN, ESQ

 Florida Bar No. 0105146

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