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UNITED STATES BANKRUPTCY COURT

SOUTHERN DISTRICT OF FLORIDA

MIAMI DIVISION

In re: CASE NO.: 20-13709-BKC-RAM

Chapter 7

LAZARO PEREZ

SSN: XXX-XX-0288

MARIA L GUZMAN

SSN: XXX-XX-9384

 Debtors. /

TRUSTEE'S MOTION TO ENLARGE TIME TO FILE

A COMPLAINT OBJECTING TO THE DEBTORS’ DISCHARGES

Joel L. Tabas, as Chapter 7 Trustee of the Bankruptcy Estate of Lazaro Perez and 

Maria L Guzman (the “Trustee”), through counsel, files this Motion to Enlarge Time to File a 

Complaint Objecting to the Debtors’ Discharges (the “Motion”) pursuant to Fed.R.Bankr.P. 

9006(b), and in support thereof, states as follows:

1. This case commenced as a Chapter 7 proceeding on March 18, 2020.

2. The §341 Meeting of Creditors initially scheduled for in-person on April 21, 

2020, but then rescheduled to, and ultimately held telephonically on, May 18, 2020 due to the 

Covid-19 pandemic. 

3. Accordingly, the deadline for the Trustee to file a complaint objecting to the 

Debtors’ discharges is July 17, 2020.

4. Additional documents and information are needed from the Debtors in order for 

the Trustee to determine whether there is any basis to file a complaint objecting to the 

Debtors’ discharge. However, despite repeated requests, the Trustee has not yet received

all requested documents and information from the Debtors. 

5. Based on the foregoing, the Trustee, through counsel, respectfully requests an

additional sixty (60) days, through and including September 15, 2020, to file a complaint 

objecting to the Debtors’ discharges.

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6. This request is made on behalf of the Trustee, and is not intended as a request 

for enlargement for any creditor.

7. Fed.R.Bankr.P. 9006(b) provides that the Court may, for cause shown, enter 

an Order enlarging time, with or without motion or notice, if the request is made before the 

expiration of the period originally prescribed or as extended.

WHEREFORE, Joel L. Tabas, as Chapter 7 Trustee of the Bankruptcy Estate of 

Lazaro Perez and Maria L Guzman, respectfully requests this Honorable Court enter an 

Order: (1) granting the instant Motion; (2) finding that cause exists to enlarge the time for the 

Trustee to file a complaint objecting to the Debtors’ discharges; (3) enlarging the time for the 

Trustee to file a complaint objecting to the Debtors’ discharges through, and including, 

September 15, 2020; and (4) granting such other and further relief as this Court deems just 

and proper.

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on July 17, 2020, a true and correct copy of the foregoing 

was served via electronic transmission to the parties who are currently on the list to receive 

e-mail notice/service for this case, and via U.S. Mail to:

Lazaro Perez

Maria L Guzman

3951 NW 176th Terrace

Miami Gardens, FL 33055-3847

Respectfully submitted,

/s/ Joshua D. Silver

Joshua D. Silver

Fla. Bar No. 100022

Tabas & Soloff, P.A.

Attorneys for Trustee, Joel L. Tabas

25 S.E. 2nd Avenue, Suite 248 

Miami, Florida 33131

Telephone: (305) 375-8171

Facsimile: (305) 381-7708

jsilver@tabassoloff.com 

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