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UNITED STATES BANKRUPTCY COURT

SOUTHERN DISTRICT OF FLORIDA

MIAMI DIVISION

In re:

DIANELIS GARCIA ROQUE,

 Debtor.

__________________________/

Case No.: 21-11965-RAM

Chapter 7

EX-PARTE APPLICATION FOR APPROVAL OF EMPLOYMENT OF 

MICHAEL P. DUNN AND DUNN LAW, P.A., AS COUNSEL 

TO MARCIA T. DUNN, CHAPTER 7 TRUSTEE 

MARCIA T. DUNN, the duly appointed Chapter 7 Trustee (the “Trustee”) for the bankruptcy 

estate of DIANELIS GARCIA ROQUE (the “Debtor”), files this ex parte application (the 

“Application”) pursuant to 11 U.S.C. §§ 327 and 330 and Fed.R.Bankr.P. 2014 and 2016, seeking 

approval of the employment of Michael P. Dunn (“Dunn”) and the law firm of Dunn Law, P.A. 

(“DLPA”) as counsel to the Trustee and states:

BACKGROUND

1. On February 27, 2021 (the “Petition Date”), the Debtor, commenced the instant 

bankruptcy case with the filing of a voluntary petition for relief under Chapter 7, Title 11 of the United 

States Bankruptcy Code. 

2. Marcia T. Dunn was appointed as the Chapter 7 Trustee of the Debtor’s bankruptcy 

estate (the “Estate”). 

3. The Debtor’s Meeting of Creditors pursuant to 11 U.S.C. § 341 was held and concluded 

on March 24, 2021.

RELIEF REQUESTED AND BASIS THEREFOR

4. It is necessary that the Trustee employ attorneys to represent the Trustee in this case to 

perform ordinary and necessary legal services required in the administration of the Estate.

5. The Trustee seeks to retain Dunn and DLPA to advise and represent her in this 

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bankruptcy case.

6. Dunn and DLPA have substantial experience in bankruptcy and reorganization cases 

before this Court and others, and are qualified to act as counsel for the Trustee.

7. The Trustee believes that the attorneys of DLPA are qualified to practice in this Court 

and are qualified to advise the Trustee on her relation with, and responsibilities to, the creditors and 

other interested parties.

8. The Trustee seeks authorization from the Court to retain DLPA to, among other things, 

consult with the Trustee concerning the administration of this case, to investigate the acts, conduct, 

assets, liabilities, and financial condition of the Debtor, and assist the Trustee in recovery of assets. 

Such services are necessary and the Trustee submits that the employment of DLPA would be in the 

best interest of the Debtor’s Estate.

9. It is in the best interest of this Estate and its economical administration that Dunn and 

DLPA, a law firm of which the Trustee is a shareholder and partner, be authorized to act as an attorney

for the Estate.

10. To the best of the Trustee’s knowledge, DLPA is “disinterested” (as such term is 

defined in 11 U.S.C. § 101(14)) as required by 11 U.S.C. § 327(a) and has no connection with the 

Debtor, the creditors or any other party in interest, except as set forth in the Declaration of Michael P. 

Dunn on behalf of Dunn Law, P.A., as Proposed Counsel to Marcia T. Dunn, Chapter 7 Trustee (the 

“Affidavit”), attached hereto as Exhibit “A.”

11. Except as otherwise disclosed herein, neither Dunn nor DLPA hold or represent any 

interest adverse to the Estate and the Trustee believes that the employment of DLPA would be in the 

best interest of the Estate.

12. DLPA has agreed to perform the foregoing services at its ordinary and usual hourly 

billing rates for the attorneys and staff working on this matter. The current hourly rates for the attorneys 

at DLPA range from $325.00 to $550.00. The current hourly rate of Michael P. Dunn, the primarily

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responsible attorney in this case, is $425.00. DLPA will incur out-of-pocket disbursements in the 

rendition of the services for which it shall seek reimbursement. DLPA recognizes that its compensation 

is subject to approval and adjustment by the Court in accordance with 11 U.S.C. § 330.

13. DLPA will apply for compensation and reimbursement of costs pursuant to 11 U.S.C. 

§§ 330 and 331, at its ordinary rates, as they may be adjusted from time to time, for services rendered

and costs incurred during its representation of the Trustee in this case.

14. Good cause exists to permit the Trustee to employ the firm of which she and Dunn are 

partners, and such employment is in the best interest of the Estate because such employment will result 

in substantial cost savings, expedited administration, and is warranted due to DLPA’s existing 

administrative involvement.

15. The Trustee believes that Dunn is qualified to practice in the Bankruptcy Court and is 

qualified to advise the Trustee on its relations with and responsibilities to the Debtor, the creditors, and 

other parties herein.

WHEREFORE, the Trustee respectfully requests that this Court enter an ex-parte order 

substantially in the form attached hereto as Exhibit “B” (i) approving the selection and employment 

of Michael P. Dunn and Dunn Law, P.A. as counsel to the Trustee in this case; and (ii) granting any 

other relief as this Court deems appropriate.

Dated: March 30, 2021 Respectfully submitted,

Marcia T. Dunn, Trustee

66 West Flagler Street

Suite 400

Miami, Florida 33130

Tel: 786-433-3866 

Fax: 786-260-0269

mdunn@dunnlawpa.com

By: /s/ Marcia T. Dunn, Trustee 

 Marcia T. Dunn, Chapter 7 Trustee

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CERTIFICATEOF SERVICE

I CERTIFY that a true and correct copy of the foregoing was served by U.S. mail on this 30th

day of March, 2021, upon the Debtor and scheduled secured creditors:

Dianelis Garcia Roque, Debtor

21221 SW 125th Path 

Miami, FL 33177

Loancare LLC

3637 Sentara Way 

Virginia Beach, VA 23452 

Synchrony Bank

PRA Receivables Management, LLC

PO Box 41021 

Norfolk, VA 23541

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

Filing (CM/ECF) on this 30th day of March, 2021, upon all registered users in this case. 

DUNN LAW, P.A.

Proposed Counsel for Marcia T. Dunn, Trustee

66 West Flagler Street, Suite 400

Miami, Florida 33130

Tel: 786-433-3866

Fax: 786-260-0269

michael.dunn@dunnlawpa.com

By: /s/ Michael P. Dunn

Michael P. Dunn, Esq.

Florida Bar No. 100705 

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