IN THE UNITED STATES BANKRUPTCY COURT

FOR THE SOUTHERN DISTRICT OF FLORIDA

WEST PALM BEACH DIVISION

In re:

RON VIGDOR CASE NO. 20-12751-MAM

CHAPTER 13

Debtor.

____________________________________/

EX PARTE MOTION FOR ORDER 

CONFIRMING THE AUTOMATIC STAY IS NOT IN EFFECT 

Toyota Motor Credit Corporation as servicer for Toyota Lease Trust (“Movant”), pursuant 

to 11 U.S.C. §362(j) and Local Rule 4001-1(C)(2)(b), seeks an order confirming the automatic 

stay is not in effect as to Movant and states: 

1. On December 15, 2017, the Debtor entered into a Motor Vehicle Lease Agreement 

(“Contract”) for the following vehicle: 2017 Lexus IS200; VIN: JTHBA1D24H5048525 (the 

“Vehicle”). A true and correct copy of the Contract is attached hereto as Composite Exhibit “A.”

2. As indicated on the title, Movant is the leaseholder on the Vehicle. A copy of the 

Title is attached hereto as Composite Exhibit “A.”

3. In the Third Amended Chapter 13 Plan (Doc. No. 43), the Debtor treated Movant 

directly outside of the Plan, assumed the underlying lease and noted that the automatic stay would 

be terminated upon confirmation of the Plan. 

4. The lease matured on December 15, 2020 and the Debtor returned the Vehicle to 

Movant on or about December 29, 2020. 

5. The Third Amended Plan was confirmed on September 24, 2020 (Doc. No. 48). 

6. Local Rule 4001-1(C)(2)(b) states: 

(b) Post-Confirmation (Ex Parte). After confirmation of a chapter 13 plan, a creditor 

may file a motion (serving all interested parties) seeking an order confirming that the 

Case 20-12751-MAM Doc 55 Filed 02/23/21 Page 1 of 3
automatic stay is not in effect. Movant may file such motion on an ex parte basis, and the 

court may enter an order granting the motion without a hearing.

7. 11 U.S.C. §362(j) states: 

(j) On request of a party in interest, the court shall issue an order under 

subsection (c) confirming that the automatic stay has been terminated.

8. Movant therefore seeks an order confirming the automatic stay is not in effect as to 

Movant’s interest in the Vehicle, pursuant to 11 U.S.C. §362(j). 

WHEREFORE, Movant, respectfully requests the Court enter an order confirming the 

termination of the automatic stay as to Movant and for such other and further relief as the Court 

deems appropriate. 

/s/Gavin N. Stewart

Gavin N. Stewart, Esquire

Florida Bar Number 52899

P.O. Box 5703

Clearwater, FL 33758

P: (727) 565-2653

F: (727) 213-9022

E:bk@stewartlegalgroup.com

Counsel for Movant

CERTIFICATE OF SERVICE

I hereby certify that a true and correct copy of the foregoing was served by CM/ECF notice 

and first class mail this 23rd day of February 2021.

/s/Gavin N. Stewart

Gavin N. Stewart, Esquire

VIA FIRST CLASS MAIL

Ron Vigdor 

5204 Lane Parke Court 

Mountain Brook, AL 35223 

VIA CM/ECF NOTICE

Mitchell J. Nowack, Esq. 

Christian J. Olson, Esq. 

8551 Sunrise Blvd. 

Case 20-12751-MAM Doc 55 Filed 02/23/21 Page 2 of 3
Suite 208 

Plantation, FL 33322 

Robin R. Weiner 

POB 559007 

Fort Lauderdale, FL 33355 

U.S. Trustee

Office of the US Trustee 

51 S.W. 1st Ave. 

Suite 1204 

Miami, FL 33130

Case 20-12751-MAM Doc 55 Filed 02/23/21 Page 3 of 3