UNITED STATES BANKRUPTCY COURT

FOR THE SOUTHERN DISTRICT OF FLORIDA

(MIAMI, DIVISION)

In re: : CASE NO.: 20-21030-AJC

:

PEDRO MANUEL BARROSO, :

: CHAPTER 7

:

Debtor. :

____________________________________/

MOTION TO REVOKE DISCHARGE 

IN ACCORDANCE WITH APPROVED SETTLEMENT

COMES NOW, Robert A. Angueira, Trustee in Bankruptcy (the “Trustee”), and files this 

Motion to Revoke Discharge in Accordance with Approved Settlement and states as follows:

1. The Debtor filed a voluntary petition under Chapter 7 of the Bankruptcy Code on

October 9, 2020 (the “Petition Date”).

2. Robert A. Angueira is the duly appointed Chapter 7 Trustee.

3. On March 25, 2021, this Court entered an Order Granting Trustee’s Motion to

Approve Stipulation to Compromise Controversy [D.E. 37] (the “Settlement Order”). 

4. The Settlement Order provides that the Debtor would pay the Trustee the total

sum of $20,000.00 as follows:

a. $10,500.00 on or before February 21, 2021, and

b. $9,600.0 to be paid in Twelve (12) equal monthly payments of $800.00 to be

made on the 21st day of each month starting on March 21, 2021 and ending on

February 21, 2022.

5. Paragraph 11 of the Settlement Order also provides as follows:

“If the Debtor fails to timely make any of the payments

described in paragraph 2, then after ten (10) days written

notice emailed or mailed to the Debtor and the Debtor’s

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counsel, the Trustee would be entitled to file a Motion and 

request a hearing seeking to revoke the Debtor’s bankruptcy 

discharge.”

6. The Debtor has defaulted on the payment terms under the Settlement Order.

7. On July 12, 2021, the Trustee mailed a default letter to the Debtor, which is

enclosed as Exhibit A.

8. As reflected in Exhibit A the Debtor failed to make the $800.00 payment that was

due on June 21, 2021. Although after the default letter the Debtor made the $800.00 payment 

corresponding to June 21, 2021, the Debtor failed to make the $800.00 payment that was due 

July 21, 2021. As a result, the Debtor is $800.00 in arrears as of the date of this Motion. 

9. The Trustee requests that the Debtor’s discharge be revoked under the terms of

the Settlement Order; unless $800.00 is received by the Trustee in clear funds by August 15, 

2021. 

WHEREFORE, the Trustee respectfully requests the entry of an Order (a) granting this 

motion; (b) revoking the Debtor’s discharge unless $800.00 in clear funds is received by the 

Trustee on or before August 15, 2021; (c) granting such other and further relief as this Court 

deems appropriate.

Respectfully submitted this 29th day of July, 2021.

ROBERT A. ANGUEIRA, P.A.

16 S.W. 1st Avenue

Miami, Florida 33130

Tel. (305) 263-3328

e-mail yanay@rabankruptcy.com

By /s/ Yanay Galban

 YANAY GALBAN, ESQ

 Florida Bar No. 0105146

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CERTIFICATE OF SERVICE

I CERTIFY that a true and correct copy of the foregoing was served by U.S. mail on this 

29th day of July, 2021, to the Debtor. 

I CERTIFY that a true and correct copy of the foregoing was served via the Notice of 

Electronic Filing on this 29th day of July, 2021, to:

• Robert A Angueira trustee@rabankruptcy.com,

fl79@ecfcbis.com;raa@trustesolutions.net;tassistant@rabankruptcy.com;richard@rabank

ruptcy.com;lillian@rabankruptcy.com

• Yanay Galban yanay@rabankruptcy.com, robert@rabankruptcy.com

• Timothy S Kingcade scanner@miamibankruptcy.com,

kingcadeserve@bellsouth.net;r46540@notify.bestcase.com

• Office of the US Trustee USTPRegion21.MM.ECF@usdoj.gov

ROBERT A. ANGUEIRA, P.A.

16 S.W. 1st Avenue

Miami, Florida 33130

Tel. (305) 263-3328

e-mail yanay@rabankruptcy.com

By /s/ Yanay Galban

 YANAY GALBAN, ESQ

 Florida Bar No. 0105146

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