UNITED STATES BANKRUPTCY COURT

SOUTHERN DISTRICT OF FLORIDA

MIAMI DIVISION

IN RE: CASE No. 20-11814-BKC-LMI

HENNY CRISTOBOL Chapter 13

Debtor

______________________/

MOTION TO REINSTATE CHAPTER 13 CASE

The Debtor, Henny Cristobol, by and through undersigned counsel, moves this honorable 

court for an Order Reinstating Chapter 13 Case and in support thereof the Debtor states the 

following:

1. Debtor filed for bankruptcy protection on February 11, 2020. 

2. On July 22, 2022, Nancy K. Neidich, Trustee filed a Notice of Non-Compliance for failure 

of the Debtor to become current with his chapter 13 plan payments. Subsequently, on July 

25, 2022, the Court issued an Order dismissing this case. 

3. The Debtor had encountered economic difficulties and could not make the payments on 

time. 

4. The Debtor has now collected the funds required to become current with his Chapter 13 

Plan and would like the opportunity to reinstate his case. 

5. The granting of this motion would not prejudice any creditor.

WHEREFORE the Debtor requests that this court enter an Order Reinstating Chapter 13 

Case.

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

CERTIFICATION OF FUNDS DUE

I undersigned affirms that the Debtors have furnished funds totaling $0.00 good towards the payment of the Debtors plan to 

Miller and Funcia, P.A. and that these funds are ready for disbursement. 

Dated this 4

th day of August 2022. 

Respectfully submitted,

Miller & Funcia, P.A.

13190 SW 134 Street, Ste 105

Miami, FL 33186

Phone: 305-274-2922

Fax: 305-273-8734

/s/

Jose P. Funcia, Esq. – FBN 698210

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CERTIFICATE OF SERVICE AND

CERTIFICATE OF COMPLIANCE WITH LOCAL RULE 9073-1(D)

I certify that true copies of DEBTOR’S MOTION TO REINSTATE CHAPTER 13 

CASE and COURT GENERATED NOTICE OF HEARING was served on August 4, 2022 as 

follows:

Electronically

Jose P Funcia on behalf of Debtor Henny Cristobol

millerfunciaecf2@gmail.com,, millerandfunciapa@ecf.inforuptcy.com

Neisi I Garcia Ramirez on behalf of Creditor NewRez LLC d/b/a Shellpoint Mortgage Servicing

Neisi.GarciaRamirez@mccalla.com, FLBKECF@mccalla.com,mccallaecf@ecf.courtdrive.com

Cassandra Jeffries on behalf of Creditor NewRez LLC d/b/a Shellpoint Mortgage Servicing

cjeffries@mwc-law.com, FLBkyPleadings@mwc-law.com;FLBKECF@mwc-law.com

Keith S Labell on behalf of Creditor NewRez LLC d/b/a Shellpoint Mortgage Servicing

klabell@raslg.com, klabell@raslg.com

Nancy K. Neidich

e2c8f01@ch13miami.com, ecf2@ch13miami.com

Office of the US Trustee

USTPRegion21.MM.ECF@usdoj.gov

Christopher P Salamone on behalf of Creditor NewRez LLC d/b/a Shellpoint Mortgage Servicing

csalamone@raslg.com, csalamone@raslg.com

Mukta Suri on behalf of Creditor NewRez LLC d/b/a Shellpoint Mortgage Servicing

Mukta.Suri@BonialPC.com, Notices.Bonial@ecf.courtdrive.com

Via First Class Mail

To all other interested parties on the attached service list - Matrix

Respectfully submitted,

Miller & Funcia, P.A.

13190 SW 134 Street, Ste 105

Miami, FL 33186

Phone: 305-274-2922

Fax: 305-273-8734

/s/

Jose P. Funcia, Esq.

FBN 0698210

Case 20-11814-LMI Doc 58 Filed 08/04/22 Page 2 of 2