________________________

Leiderman Shelomith Alexander + Somodevilla, PLLC

Miami | Fort Lauderdale

UNITED STATES BANKRUPTCY COURT

SOUTHERN DISTRICT OF FLORIDA

Miami Division

www.flsb.uscourts.gov

In re:

EDUARDO H LORENTE,

Debtor.

___________________________________/

Case No. 21-17232-BKC-RAM

Chapter 7

TRUSTEE'S MOTION FOR EXTENSION OF TIME TO 

FILE COMPLAINT OBJECTING TO DEBTOR’S DISCHARGE

Barry E. Mukamal, Chapter 7 Trustee (the “Trustee”) for the bankruptcy estate of 

Eduardo H Lorente (the “Debtor”), by counsel, pursuant to Fed. R. Bankr. P. 4004, requests 

the Court enter an order extending the Trustee’s deadline within which to file a complaint 

objecting to the Debtor’s discharge under 11 U.S.C. § 727, up to and including January 7, 

2022 (the “Motion”), and states as follows:

1. On July 27, 2021, the Debtor filed a voluntary petition for relief under Chapter 

7 of the United States Bankruptcy Code (the “Petition Date”). Barry E. Mukamal was 

appointed interim Trustee and became permanent trustee by operation of law. 

2. On August 31, 2021, the Section 341 Meeting of Creditors was held and 

concluded [ECF No. 11].

3. The present deadline for the Trustee to file a complaint objecting to the Debtor’s 

discharge is November 1, 2021.

4. As part of the Trustee’s due diligence and review of the documentation 

provided by the Debtor at the Trustee’s request, it has come to the Trustee’s attention that 

the Debtor apparently failed to disclose digital currency accounts at both Coinbase and 

Gemini Exchange (collectively the “Crypto Accounts”). A review of the Debtor’s bank 

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________________________

Leiderman Shelomith Alexander + Somodevilla, PLLC

Miami | Fort Lauderdale

statements for the six (6) months prior to the Petition Date reflect transfers from Coinbase in 

the amount of $5,120.00 and Gemini Exchange in the amount of $1,131.00.

5. The Trustee has requested that the Debtor amend his schedules to include the 

missing accounts and provide to the Trustee statements for the Crypto Accounts for a period 

of six (6) months prior to the petition date. As of the filing of this Motion, the Debtor has not 

amended his schedules to disclose the missing Crypto Accounts, nor has he provided the 

requested statements to the Trustee.

6. Accordingly, the Trustee requests an extension of time to file a complaint 

objecting to the Debtor’s discharge, up to and including January 7, 2022.

7. The Trustee contacted the Debtor’s counsel to obtain his agreement to the 

relief requested, but Debtor’s counsel did not agree to the requested extension and as such, 

a hearing will be required on this Motion.

WHEREFORE, the Trustee respectfully requests that the Court enter an order 

extending the deadline within which to file a complaint objecting to the Debtor’s discharge, up 

to and including January 2, 2022, and for such other and further relief as the Court deems just 

and proper. 

Dated: November 1, 2021 LSAS ATTORNEYS

Attorneys for the Trustee

2 South Biscayne Boulevard, Suite 2300

Miami, FL 33131

Telephone (305) 894-6163

Facsimile (305) 503-9447

By:_________/s/__________________

CHRISTIAN SOMODEVILLA

Florida Bar No. 59539

cs@lsaslaw.com

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________________________

Leiderman Shelomith Alexander + Somodevilla, PLLC

Miami | Fort Lauderdale

CERTIFICATE OF SERVICE

I hereby certify that a true and correct copy of the foregoing motion was served on 

November 1, 2021 to all parties on the list to receive e-mail notice/service for this case, via 

the Notice of Electronic Filing (which is incorporated herein by reference) and via U.S. Mail 

to Eduardo H Lorente, 5801 W 16th Lane #1, Hialeah, FL 33012-7911. 

By:_________/s/__________________

Christian Somodevilla, Esq.

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