35670705:1

UNITED STATES BANKRUPTCY COURT

SOUTHERN DISTRICT OF FLORIDA

FORT LAUDERDALE DIVISION

Marlen Paradoa, Case No.: 20-17188-PDR

Chapter 7

 Debtor.

____________________________/

TRUSTEE’S AGREED EX PARTE MOTION FOR EXTENSION OF TIME 

FOR THE TRUSTEE AND OFFICE OF THE UNITED STATES TRUSTEE TO 

FILE AN ADVERSARY COMPLAINT AGINST THE DEBTOR TO DENY DISCHARGE 

UNDER 11 U.S.C. §727(a)

The Trustee, Chad S. Paiva, files this Agreed Ex Parte Motion for Extension of 

Time for the Trustee and Office of the United States Trustee to File an Adversary 

Complaint Against the Debtor to Deny Discharge Under 11 U.S.C. §727(a), pursuant to 

F.R.B.P. 4004 and Local Rule 9013-1(C)(1) and (6), and states:

1. This bankruptcy case was commenced by the filing of a voluntary chapter 7 

petition by the debtor on June 30, 2020.

2. Chad Paiva is the duly qualified Trustee in this case.

3. Pursuant to the Notice of Chapter 7 Bankruptcy Case (DE#2), the current 

deadline to object to the debtor’s discharge is October 5, 2020.

4. On September 9, 2020, the Office of the United States Trustee filed a 

Motion to Dismiss this case under 11 U.S.C. §707(b) (DE#18). The Motion to Dismiss is 

scheduled for hearing on October 1, 2020 which is only four (4) days prior to the deadline 

to file an adversary complaint against the debtor to deny discharge under 11 U.S.C. 

§727(a).

5. The Trustee and Office of the United States Trustee believe that grounds 

may exist to seek a denial of the Debtor’s discharge, however, it will not be necessary to 

pursue a denial of the debtor’s discharge if the Court dismisses the case either at the 

October 1, 2020 hearing or a subsequently scheduled evidentiary hearing. 

6. Alternatively, should the Court deny the Motion to Dismiss at the hearing on 

October 1, 2020, there will not be sufficient time to take the debtor’s 2004 examination, 

and prepare and file an adversary complaint against the debtor on or before the current 

deadline should the Trustee and Office of the United States Trustee decide to pursue a 

denial of the debtor’s discharge. 

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7. Based on the foregoing, the Trustee requests on behalf of himself and the 

Office of the United States Trustee a 60 day extension of time up through and including 

December 4, 2020 to file an adversary complaint against the debtor to deny discharge 

under 11 U.S.C. §727(a).

8. THE DEBTOR, THROUGH HER COUNSEL, CONSENTED IN WRITING

TO THE EXTENSION REQUESTED HEREIN ON SEPTEMBER 15, 2020. 

9. The Trustee has uploaded an Agreed Ex-Parte Order granting the extension 

requested herein. 

WHEREFORE, the Trustee requests that this Court enter an Order granting the 

relief requested herein, and for and for such other relief as the Court deems just and 

proper. 

 I HEREBY CERTIFY that a true and correct copy of the foregoing has been 

furnished by regular U.S. Mail and CM/ECF to all parties listed below in the manner listed 

below on this the 21

ST day of September 2020.

 By: /S/ Chad S. Paiva_____

 Chad S. Paiva.

 Chapter 7 Trustee

 6526 S. Kanner Highway, #376

 Stuart, FL 34997

 Telephone: (561) 762-4118

 Email: trustee.paiva@gmail.com

Via CM/ECF

The following is a list of parties who are currently on the list to receive email notice/service 

for this case:

• US Trustee’s Office USTPRegion21.MM.ECF@doj.gov

• Adisley M. Cortez-Rodriquez, Esq. adisley.m.cortez-rodriquez@usdoj.gov

• Robert Sanchez, Esq. court@bankruptcyclinic.com

• Brittany Lee Hynes, Esq. blh@trippscott.com

Via Regular Mail

Marlen Paradoa

4765 NW 115th Way

Sunrise, FL 33323-2704

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