UNITED STATES BANKRUPTCY COURT

SOUTHERN DISTRICT OF FLORIDA

MIAMI-DADE DIVISION

In re:

HENRY GONZALEZ, 

Debtor. 

_______________________/

Case Number 21-12885-RAM

Chapter 7 

MOTION TO RE-OPEN CASE TO AMEND SCHEDULES

TO ADD OMITTED PRE-PETITION CREDITORS

Debtor, HENRY GONZALEZ, through undersigned counsel, moves this Court to reopen 

this Chapter 7 Bankruptcy to amend the Schedules to add omitted creditors, and states: 

1. On March 29, 2021, Debtor, HENRY GONZALEZ, filed this Chapter 7

Bankruptcy action. 

2. On July 2, 2021, this Bankruptcy case was discharge.

3. Debtor needs to reopen the Bankruptcy proceeding to amend the Schedules to add

omitted pre-petition creditors. 

4. No party will be prejudiced by the re-opening of this bankruptcy action to amend

the Schedules to add omitted pre-Petition creditors. 

WHEREFORE, Debtor, HENRY GONZALEZ, moves this Court for an Order to re-open 

this bankruptcy action to amend Schedules to add omitted pre-Petition creditors (proposed Order 

attached as Exhibit "A").

CERTIFICATE PURSUANT TO LOCAL

RULE 9011-4(B)

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) 

MARIA I. ESCOTO-CASTIELLO, P.A.

Counsel for Debtor 

2000 South Dixie Highway, Suite 104-A 

Miami, Florida 33133 

Telephone: (305) 860-0991 

Facsimile: (305) 860-0953 

Email: maria@mec-lawfirm.com

/s/ Maria I. Escoto-Castiello 

Maria I. Escoto-Castiello, Esq.

Florida Bar No.: 959839 

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EXHIBIT A

Proposed Order

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LF-37 (rev. 01/17/18)

Page 1 of 2

UNITED STATES BANKRUPTCY COURT 

SOUTHERN DISTRICT OF FLORIDA

www.flsb.uscourts.gov

In re:

Case No. 21−12885−RAM

HENRY GONZALEZ Chapter 7

 Debtor /

ORDER REOPENING CASE TO AMEND SCHEDULES

TO ADD OMITTED CREDITOR(S)

THIS MATTER came before the Court: 

upon the debtor’s Motion to Reopen Case to Amend Schedules to Add 

Omitted Creditors (the “Motion”) pursuant to 11 U.S.C. §350, Bankruptcy 

Rule 5010, and Local Rule 5010-1(B), filed pursuant to Local Rule 9013-

1(D)(3)(i). Accordingly, it is

for hearing on ______________ upon the debtor’s Motion to Reopen 

Case to Amend Schedules to Add Omitted Creditors (the “Motion”) 

pursuant to 11 U.S.C. §350, Bankruptcy Rule 5010, and Local Rule 5010-

1(B). For the reasons stated on the record, it is

ORDERED as follows:

1. This case is reopened. No trustee shall be appointed.

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LF-37 (rev. 01/17/18) Page 2 of 2

 2. Within 14 days from the entry of this order, the debtor shall amend the 

schedules (and pay applicable amendment fee) to add the name(s) and address(es) of 

the creditor(s) and related information previously omitted from the original schedules. 

A supplemental matrix of creditors as required by the “Clerk's Instructions for Preparing, 

Submitting and Obtaining Service Matrices” and Local Form “Debtor’s Notice of 

Compliance with Requirements for Amending Creditor Information” must accompany 

the amended schedules. 

3. The debtor (or the debtor’s attorney) is directed to furnish to all affected 

creditors a complete copy of (a) this order; (b) the clerk’s original notice of meeting of 

creditors as required under Local Rule 1009-1(D); and (c) the order discharging the 

debtor. The debtor shall file a certificate of service as required under Local Rule 2002-

1(F).

4. Each affected creditor shall have sixty (60) days from the date of service 

of this order to file an adversary proceeding to determine whether the debt subject to 

amendment is dischargeable under 11 U.S.C. §523(a)(3)(B) because it is of a kind 

specified in paragraph (2), (4), or (6) of 11 U.S.C. §523(a). If a creditor fails to timely file 

such a complaint, then such creditor has waived the right to argue that the debt subject 

to such amendment is excepted from discharge under §523(a)(3)(b).

###

Submitted by:

Maria I. Escoto-Castiello, Esq.

2000 South Dixie Highway, Suite 104-A

Miami, Florida 33133

Attorney Escoto-Castiello is directed to serve copies of this order on all interested parties.

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