UNITED STATES BANKRUPTCY COURT 

SOUTHERN DISTRICT OF FLORIDA 

WEST PALM BEACH DIVISION 

www.flsb.uscourts.gov 

In re: 

ROBERT W. SZOSTAK 

 Debtor. 

Chapter 7 

Case No. 22-11098-MAM 

 / 

FIFTH AGREED EX PARTE MOTION TO EXTEND TIME TO OBJECT 

TO DISCHARGEABILITY OF DEBT PURSUANT TO 11 U.S.C. § 523 AND 

TO DISCHARGE PURSUANT TO 11 U.S.C. § 727 

 Creditors, MicroBilt Corporation and Princeton Alternative Funding, LLC 

(together, the “Creditors”), through undersigned counsel, pursuant to 11 U.S.C. § 523 and 11 

U.S.C. § 727, with the consent of the Debtor, respectfully requests entry of a fifth agreed ex parte

order permitting an additional thirty (30) days in which to object to dischargeability of debt 

pursuant to 11 U.S.C. § 523 and/or for objection to discharge pursuant to 11 U.S.C. § 727, 

Bankruptcy Rules 4004 and 4007, and Local Rule 9013-1(C)(1) and 9013-1(C)(6), and in support 

thereof, states: 

1. The original deadline to commence an adversary proceeding to object to debtors’ 

discharge or the dischargeability of any debt was June 27, 2022, which was extended to July 27, 

2022; again to August 31, 2022; again to September 30, 2022; and again to October 31, 2022, 

pursuant to the Court’s entry of Orders [ECF Nos. 48, 53, 56, and 63] granting the Agreed Ex Parte 

Motion to Extend Time to Object to Dischargeability of Debt Pursuant to 11 U.S.C. § 523 and to 

Discharge Pursuant to 11 U.S.C. § 727 (the “First Agreed Motion”) [ECF No. 47]; the Second 

Agreed Ex Parte Motion to Extend Time to Object to Dischargeability of Debt Pursuant to 11 

U.S.C. § 523 and to Discharge Pursuant to 11 U.S.C. § 727 (the “Second Agreed Motion”) [ECF 

Case 22-11098-MAM Doc 66 Filed 10/25/22 Page 1 of 7
No. 51]; the Third Agreed Ex Parte Motion to Extend Time to Object to Dischargeability of Debt 

Pursuant to 11 U.S.C. § 523 and to Discharge Pursuant to 11 U.S.C. § 727 (the “Third Agreed 

Motion”) [ECF No. 55]; and the Fourth Agreed Ex Parte Motion to Extend Time to Object to 

Dischargeability of Debt Pursuant to 11 U.S.C. § 523 and to Discharge Pursuant to 11 U.S.C. 

§ 727 (the “Fourth Agreed Motion”) [ECF No. 61], respectively. 

2. As explained in the First Agreed Motion, Second Agreed Motion, Third Agreed 

Motion, and Fourth Agreed Motion, Creditors filed a Notice of Rule 2004 Examination [ECF No. 

44] (the “2004 Notice”) seeking production of documents and examination of the Debtor, to which 

the Debtor raised informal objections and which objections have been resolved by the parties 

pursuant to an agreement limiting the scope of the examination given that “Creditors”/Interested 

Parties have been granted stay relief by agreement under the “Pending Proceedings” doctrine. 

Such agreement is reflected in an agreed motion for protective order limiting the scope of the Rule 

2004 examination (the “Motion for Protective Order”) [ECF No. 58]. The Motion for Protective 

Order was granted on September 12, 2022 (the “Protective Order”) [Doc. No. 59]. 

3. With the Protective Order now in place, the parties have been working to finalize 

an agreed timeline for completing the limited 2004 Exam and production of documents. In 

consideration of the parties’ further cooperate efforts, Debtor has agreed to the extension of the 

523 and 727 deadlines as requested by the Creditors. 

4. Creditors, with the consent of the Debtor, respectfully request an extension of thirty 

(30) days, or until November 30, 2022, to object to the Debtor’s discharge and/or to the 

dischargeability of any debt for the reasons enumerated above. 

5. The Debtor and his counsel have agreed to the requested relief pursuant to Local 

Rule 9013-1(C)(6). 

Case 22-11098-MAM Doc 66 Filed 10/25/22 Page 2 of 7
6. A proposed agreed ex parte order granting the relief requested is attached as 

required by Local Rule 5005-1(G)(1)(a). 

WHEREFORE, Creditors respectfully request entry of an Agreed Ex Parte Order

extending the deadlines for the filing of a complaint objecting to the dischargeability of certain 

debt pursuant to 11 U.S.C. § 523 and for filing a complaint objecting to debtor’s discharge pursuant 

to 11 U.S.C. § 727, for an additional thirty (30) days, or until November 30, 2022, and for such 

other relief as this Court deems appropriate.

Dated: October 25, 2022 Respectfully submitted, 

/s/ Alexis A. Leventhal 

Alexis A. Leventhal (Fla. Bar No. 108064) 

Reed Smith LLP 

225 Fifth Avenue, Suite 1200 

Pittsburgh, PA 15222 

Telephone: (412) 288-3131 

Facsimile: (412) 288-3063 

Email: aleventhal@reedsmith.com 

Counsel for MicroBilt Corporation and 

Princeton Alternative Funding, LLC

Case 22-11098-MAM Doc 66 Filed 10/25/22 Page 3 of 7
CERTIFICATE OF SERVICE 

 I HEREBY CERTIFY that on October 25, 2022, a copy of the foregoing was electronically 

filed with the Court using the CM/ECF system, which sent notification to all parties of interest 

who are participating in the CM/ECF system, and by First Class U.S. mail to all parties on the 

attached mailing service list. 

 /s/ Alexis A. Leventhal 

 Alexis A. Leventhal 

First Class U.S. Mailing List: 

Robert W. Szostak 

3191 S Dixie Hwy, Apt 515 

West Palm Beach, FL 33405-1596 

Case 22-11098-MAM Doc 66 Filed 10/25/22 Page 4 of 7
EXHIBIT A 

Case 22-11098-MAM Doc 66 Filed 10/25/22 Page 5 of 7
 

[PROPOSED ORDER] 

UNITED STATES BANKRUPTCY COURT 

SOUTHERN DISTRICT OF FLORIDA 

WEST PALM BEACH DIVISION 

www.flsb.uscourts.gov 

In re: 

ROBERT W. SZOSTAK, 

 Debtor. 

Case No. 22-11098-MAM 

Chapter 7 

 / 

FIFTH AGREED ORDER GRANTING CREDITOR MICROBILT CORPORATION 

AND PRINCETON ALTERNATIVE FUNDING, LLC’S FIFTH AGREED EX PARTE

MOTION TO EXTEND TIME TO OBJECT TO DISCHARGEABILITY OF DEBT 

PURSUANT TO 11 U.S.C. § 523 AND TO DISCHARGE PURSUANT TO 11 U.S.C. § 727 

[ECF NO. ] 

THIS MATTER came before the Court, ex parte, without a hearing, upon the Fifth Agreed 

Ex Parte Motion to Extend Time to Object to Dischargeability Pursuant to 11 U.S.C. § 523 and 

Discharge Pursuant to 11 U.S.C. § 727 [ECF No. ] (the “Motion”) filed by Creditors MicroBilt 

Case 22-11098-MAM Doc 66 Filed 10/25/22 Page 6 of 7
 - 2 - 

Corporation and Princeton Alternative Funding, LLC (together, the “Creditors”) and the Court, 

having considered the Motion, noting that the Debtor has agreed to the requested relief, it is hereby 

ORDERED: 

1. The Motion is Granted. 

2. The time within which Creditors may file a complaint objecting the dischargeability 

of certain debt pursuant to 11 U.S.C. § 523, and/or for objecting to Debtors’ discharge pursuant to 

11 U.S.C. § 727, is hereby extended to November 30, 2022. 

### 

Submitted by: 

Alexis A. Leventhal (Fla. Bar No. 108064) 

Reed Smith LLP 

225 Fifth Avenue, Suite 1200 

Pittsburgh, PA 15222 

Telephone: (412) 288-3131 

Facsimile: (412) 288-3063 

Email: aleventhal@reedsmith.com 

Attorney Leventhal is directed to serve a copy of this order on all interested parties within three 

(3) days of entry and to file a certificate of service thereon.

Case 22-11098-MAM Doc 66 Filed 10/25/22 Page 7 of 7