UNITED STATES BANKRUPTCY COURT

SOUTHERN DISTRICT OF FLORIDA

IN RE: CASE NO. 22-10014-BKC-SMG

LORENZO ALLEN, ` In proceedings under Chapter 13

 FORT LAUDERDALE DIVISION

Debtor.

_______________________________/

EMERGENCY HEARING REQUESTED

DEBTOR’S MOTION TO REINSTATE THE CHAPTER 13 CASE

Basis for Emergency: The Debtor is in possession of a Final Judgment evidencing a

foreclosure sale on February 9, 2022. The Debtor will suffer permanent and irreparable

harm if the home is sold. The Debtor requests this matter be heard no later than February

8, 2022.

COMES NOW, Lorenzo Allen, the Debtor, by and through undersigned counsel, and

moves this Court to Reinstate the Chapter 13 Case, and in support thereof states as grounds the

following:

1. On January 3, 2022, the Debtor filed a voluntary chapter 13 bankruptcy under Title 11

of the United States Code.

2. On January 27, 2022, the Court entered an Order Dismissing the case was dismissed

for failure to file the Chapter 13 Plan and other documents.

3. The undersigned has filed all documents, and holding the first chapter 13 payment. 

The filing fee to the clerk of court has been paid.

4. Based on the foregoing, the Debtor wishes to reinstate the case and resolve his

liabilities.

5. As of the date of this Motion, all the required documents have been filed with the

Court.

6. The undersigned counsel pursuant to Local Rule 9013-1(E)(3)(a), certifies

that the Debtor has tendered the sum necessary to the undersigned to bring his case

current under the modified plan as of the date of this Motion.

WHEREFORE, the Debtor respectfully requests this Court to reinstate the Chapter 13

case. 

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 I hereby certify that I am admitted to the Bar of the United States District Court of the

Southern District of Florida and I am in compliance with the additional qualifications to practice

in this Court as set forth in Local Rule 2090-1(A). 

Bigge & Rodriguez, PA

Attorneys for the Debtor

915 Middle River Dr., Ste. 401

Fort Lauderdale, FL 33304

(954)400-7322

(954)400-5449 Facsimile

brpa@biggerodriguez.com

By: Robert J. Bigge, Jr. 

Robert J. Bigge, Jr.

 Florida Bar No. 906610

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Lorenzo A Allen

6207 NW 66 way

Parkland, FL 33067

Robin R. Weiner, Trustee

(electronically)

Office of the US Trustee 

(electronically) 

Aldridge & Connors

1615 S. Congress Ave.

Ste. 200

Delray Beach, FL 33445

Atty General of the US

950 Pennsylvania Ave NW, #4400

Washington, DC 20530-0001

Gilbert & Caddy, P.A.

1720 Harrison St.

19th Floor, Penthouse B

Hollywood, FL 33020

Internal Revenue Service

POB 7346

Philadelphia, PA 19101

Mercury Credit Card

POB 84064

Columbus, GA 31908

Ocwen Loan Servicing L

1661 Worthington Rd Suite 100

West Palm Beach, FL 33409

Real Time Resolutions

5420 Lbj Freeway #1010

Dallas, TX 75240

Roger Morris & Ziegler

1401 E Broward Blvd

Ste 300

Fort Lauderdale, FL 33301

Special Assistant US Attorney

Associate Area Counsel

1000 S Pine Island Rd #300

Plantation, FL 33324

Timberoof Roofing Co. Inc.

4261 NW 74th Ave

Lauderhill, FL 33319

US Attorney

Southern District of Florida

99 NE 4 St

Miami, FL 33132

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