UNITED STATES BANKRUPTCY COURT

SOUTHERN DISTRICT OF FLORIDA

WEST PALM BEACH DIVISION

www.flsb.uscourts.gov

In re:

STUART ROY MILLER,

Debtor.

/

Case No.: 20-22497-EPK

Chapter 7

AGREED EX PARTE MOTION FOR EXTENSION

OF TIME TO FILE ADVERSARY COMPLAINT AGAINST DEBTOR 

TO DETERMINE DEBT NON-DISCHARGEABLE UNDER 11 U.S.C. § 523(a) 

Chad S. Paiva (the “Trustee”), as Trustee in Bankruptcy for Denials Recovery Group, Inc. 

(“Denials Recovery”), through undersigned counsel, files pursuant to F.R.B.P 4004 and 4007, and 

Local Rule 9013-1(C)(1) and (6), this Agreed Ex-Parte Motion for Extension of Time to File 

Adversary Complaint Against Debtor Stuart Roy Miler (the “Debtor”) to Determine Debt NonDischargeable under 11 U.S.C. § 523(a), and states:

1. This bankruptcy case was commenced by the Debtor’s filing of a voluntary chapter 

7 petition on November 13, 2020. The Debtor is the principal of Denials Recovery. The Trustee 

may have claims against the Debtor on behalf of Denials Recovery.

2. The current deadline for the Trustee to file an adversary complaint against the 

Debtor to determine debt non-dischargeable is February 6, 2021.

3. The Trustee has scheduled a Rule 2004 Examination of the Debtor for January 29, 

2021, and documents have been requested from the Debtor as well. The Trustee must review the 

documents, take the Rule 2004 Examination, and may need to investigate additional matters after 

this investigation in order to determine if an objection to the dischargeability of the debt is 

necessary. The Trustee requests an extension through March 2, 2021 to file any § 523(a) action. 

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3. On January 12, 2021, the Debtor’s counsel agreed to an extension of these deadlines 

through and including March 2, 2021 for the Trustee.

WHEREFORE Chad S. Paiva, as Trustee in Bankruptcy for Denials Recovery Group, Inc., 

respectfully requests that this Court enter an Order extending the deadline for him to file an 

adversary complaint against the Debtor to determine debt non-dischargeable under 11 U.S.C. §

523(a) through and including March 2, 2021, and for such other relief as the Court deems just and 

proper. 

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 before this Court set forth in Local Rule 2090-1(A).

I HEREBY certify that a copy of the foregoing has been furnished this 19th day of January, 

2021 to all the parties in interest via CMECF Notice, or via U.S. regular mail as indicated below.

FENDER, BOLLING, & PAIVA, P.A.

/s/ G. Steven Fender

G. STEVEN FENDER, ESQ.

Florida Bar No. 060992

MICHAEL H. BOLLING, ESQ.

Florida Bar No. 117626

Attorneys for Chad S. Paiva

P.O. Box 1545

Ft. Lauderdale, FL 33302

Telephone: (407) 810-2458

Email: steven.fender@fender-law.com

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SERVICE LIST

Electronic Mail Notice List

Alexandra D Blye on behalf of Creditor APPLIED REVENUE ANALYTICS, LLC

ablye@carltonfields.com, kdemar@carltonfields.com;wpbecf@cfdom.net

Heidi A Feinman on behalf of U.S. Trustee Office of the US Trustee

Heidi.A.Feinman@usdoj.gov

Robert C Furr, Esq on behalf of Debtor Stuart Roy Miller

ltitus@furrcohen.com, 

atty_furrcohen@bluestylus.com;cworkinger@furrcohen.com;staff1@furrcohen.com

Tarek Kirk Kiem

trustee@kiemlaw.com, tarek.kiem@gmail.com,ctk11@trustesolutions.net

Corali Lopez-Castro, Esq 

clc@kttlaw.com, rcp@kttlaw.com

Office of the US Trustee

USTPRegion21.MM.ECF@usdoj.gov

Chad S. Paiva

trustee.paiva@gmail.com, sramirez.fbp@gmail.com;ecf.alert+Paiva@titlexi.com

Bradley S Shraiberg on behalf of Creditor Office Depot

bss@slp.law, 

dwoodall@slp.law;dwoodall@ecf.courtdrive.com;dlocascio@slp.law;pmouton@slp.law

Via US Mail

BMW Bank of North America

c/o AIS Portfolio Services, LP

4515 N Santa Fe Ave. Dept. APS

Oklahoma City, OK 73118

Walter V. Williams

Thomas Williams McConnell PLLC

114 W. 7th Street, Ste 1100

Austin, TX 78701

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