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UNITED STATES BANKRUPTCY COURT 

SOUTHERN DISTRICT OF FLORIDA

FORT LAUDERDALE DIVISION 

www.flsb.uscourts.gov

In re: 

LORENZO A. ALLEN 

Debtor

________________________________/

Case No.: 22-10014-SMG

Chapter 13

BANK OF NEW YORK MELLON F/K/A THE BANK OF NEW YORK AS SUCCESSOR 

TO JP MORGAN CHASE, N.A. AS TRUSTEE FOR ASSET BACKED FUNDING 

CORPORATION ASSET-BACKED CERTIFICATES, SERIES 2003-AHL1’S MOTION 

TO CONTINUE OCTOBER 19, 2023 HEARING ON DEBTOR’S MOTION FOR 

CONTEMPT AND SANCTIONS DUE TO WILLFUL VIOLATION OF THE 

AUTOMATIC STAY 

Bank of New York Mellon f/k/a the Bank of New York as Successor to JP Morgan Chase 

Bank, N.A., as Trustee for Asset Backed Funding Corporation Asset-Backed Certificates, Series 

2003-AHL1 (“BoNY”) pursuant to L.R. 5071-1 moves for a continuance of the hearing scheduled 

for October 19, 2023 at 1:00 P.M. on the Debtor’s Motion for Contempt and Sanctions due to 

Willful Violation of the Automatic Stay (the “Motion for Contempt”) and states as follows: 

1. The Motion for Contempt was filed on September 15, 2023 and scheduled for 

hearing at that time [ECF 104 & 105].

2. The undersigned counsel is presently scheduled to attend mediation in Lee County 

on October 19, 2023 at the same time in the following two cases: 

Dealers Greatest Assets, Inc. v. Metro Honda, Case No.: 22-SC-007733; and

Dealers Greatest Assets, Inc. v. Honda of Toms River, Case No.: 22-SC-007732.

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3. The orders requiring the undersigned counsel to attend mediation were entered on 

August 17, 2023 and therefore, the undersigned counsel cannot move the mediations to 

accommodate the hearing on the Motion for Contempt.

4. This is BoNY’s first request for a continuance of a hearing on the Motion for 

Contempt. 

5. The undersigned counsel’s client consents to the relief sought herein. 

6. The undersigned counsel has not conferred with the Debtor regarding the relief 

sought herein as the Debtor is prosecuting the Motion for Contempt pro se. 

7. A proposed order is submitted herewith as Exhibit “A.”

WHEREFORE, the Bank of New York Mellon f/k/a the Bank of New York as Successor 

to JP Morgan Chase Bank, N.A., as Trustee for Asset Backed Funding Corporation Asset-Backed 

Certificates, Series 2003-AHL1 moves for a continuance of the October 19, 2023 hearing on the 

Motion for Contempt and Sanctions due to Willful Violation of the Automatic Stay.

Respectfully Submitted,

/s/ Siobhan E. P. Grant 

Siobhan E. P. Grant 

Florida Bar No.: 68892

sgrant@hinshawlaw.com

HINSHAW & CULBERTSON LLP

2525 Ponce de Leon, 4th Floor

Coral Gables, FL 33134

Tel: (305) 428-5118

Attorneys for Bank of New York Mellon f/k/a 

the Bank of New York as Successor to JP 

Morgan Chase Bank, N.A., as Trustee for 

Asset Backed Funding Corporation AssetBacked Certificates, Series 2003-AHL1

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Certificate of Service

I HEREBY certify that on October 10, 2023, I served the foregoing Motion in the manner 

specified below to the particular parties: 

Via US Mail 

Lorenzo A. Allen 

6207 NW 66th Way 

Parkland, Florida 33067

Via CM/ECF 

Robin Weiner

Chapter 13 Trustee

PO Box 559007

Ft. Lauderdale, FL 33355

Via CM/ECF 

Chad Van Horn 

500 NE 4th Street #200

Ft. Lauderdale, FL 33301

Via CM/ECF

Office of US Trustee

51 SW 1st Avenue 

Suite 1204

Miami, FL 33130

By: /s/ Siobhan E. P. Grant

Siobhan E. P. Grant

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