UNITED STATES BANKRUPTCY COURT 

SOUTHERN DISTRICT OF FLORIDA 

MIAMI DIVISION

www.flsb.uscourts.gov

IN RE: Case No.: 21-14169-AJC 

MICHAEL PETRUSHA and 

TRACEY PETRUSHA, 

 Debtors./ 

Chapter 7 

AGREED EX PARTE MOTION FOR EXTENSION 

OF TIME TO FILE A COMPLAINT OBJECTING TO DEBTORS’ 

DISCHARGE AND TO OBJECT TO DEBTORS’ CLAIMED EXEMPTIONS 

 Soneet R. Kapila, the Chapter 7 Trustee (the "Trustee") for the estate of Michael Petrusha 

and Tracey Petrusha (the "Debtors"), through undersigned counsel, moves, on an ex-parte basis, 

pursuant to Federal Rules of Bankruptcy Procedure 4003 and 4004, and Local Rule 9013-

1(C)(1), for the entry of an order extending the Trustee’s and United State Trustee’s deadline to 

file a complaint objecting to Debtors’ discharge and Trustee’s deadline to object to Debtors’ 

claimed exemptions. In support of this motion (the “Motion”), the Trustee states: 

1. The Debtors filed a voluntary petition under Chapter 7 of Title 11 of the United 

States Code on April 30, 2021. 

2. The Trustee conducted the Section 341 Meeting of Creditors on June 2, 2021. 

3. The current deadline for the Trustee and the United States Trustee to file a 

complaint objecting to the Debtors’ discharge is August 2, 2021. 

4. The current deadline for the Trustee to file an objection to the Debtors’ claimed 

exemptions is July 2, 2021. 

5. Counsel was recently retained and has requested documents and requests an 

extension of time so that the Trustee has sufficient time to receive and review the documents, 

complete his analysis, request additional documents if necessary, and file an objection, if any, to 

the Debtors’ discharge and/or claimed exemptions. 

Case 21-14169-PGH Doc 21 Filed 06/30/21 Page 1 of 3
6. Accordingly, the Trustee requests an extension of time for the Trustee and the 

United States Trustee to object to the Debtors’ discharge pursuant to Section 727 of the 

Bankruptcy Code through and including September 1, 2021, as well as the Trustee’s deadline to 

object to the Debtors’ claim of exemptions through and including August 2, 2021. 

7. The Debtors consent to the extension of time requested herein. 

8. Undersigned certifies that the Motion is brought in good faith and not for 

purposes of delay. 

 WHEREFORE, the Trustee respectfully requests entry of an order (a) granting the 

Motion; (b) extending the deadline for the Trustee and the United States Trustee to file a 

complaint objecting to Debtors’ discharge through and including September 1, 2021; (c) 

extending the deadline for the Trustee to object to the Debtors’ claimed exemptions through and 

including August 2, 2021; (d) and granting such other and further relief as the Court deems just 

and proper. 

CERTIFICATE OF SERVICE 

 I HEREBY CERTIFY that a true and correct copy of the foregoing was served on all 

counsel of record or pro se parties identified on the attached Service List via U.S. Mail and/or 

the Court’s CM/ECF notification to those parties who are registered CM/ECF participants in this 

case on June 30, 2021. 

Dated: June 30, 2021 Respectfully Submitted, 

Markowitz Ringel Trusty & Hartog, P.A. 

 Counsel to Chapter 7 Trustee 

 9130 South Dadeland Boulevard, Suite 1800 

 Miami, Florida 33156 

 Tel. (305) 670-5000 // Fax. (305) 670-5011 

 By: /s/ John H. Lee 

John H. Lee, Esq. 

Florida Bar No. 91795 

 jlee@mrthlaw.com

 

Case 21-14169-PGH Doc 21 Filed 06/30/21 Page 2 of 3
 In re: MICHAEL PETRUSHA AND TRACEY PETRUSHA 

Case No.: 21-14169-AJC 

Service List 

21-14169-AJC Notice will be electronically mailed to: 

Ross R Hartog on behalf of Trustee Soneet Kapila 

rhartog@mrthlaw.com, ecfnotices@mrthlaw.com; gruiz@mrthlaw.com;mrthbkc@gmail.com; 

lgener@mrthlaw.com;ycandia@mrthlaw.com;rhartog@ecf.courtdrive.com 

Soneet Kapila 

trustee@kapilaco.com, ecf.alert+Kapila@titlexi.com 

Timothy S Kingcade, Esq on behalf of Debtor Michael Petrusha 

scanner@miamibankruptcy.com, kingcadeserve@bellsouth.net;r46540@notify.bestcase.com 

Timothy S Kingcade, Esq on behalf of Joint Debtor Tracey Petrusha 

scanner@miamibankruptcy.com, kingcadeserve@bellsouth.net;r46540@notify.bestcase.com 

Office of the US Trustee 

USTPRegion21.MM.ECF@usdoj.gov 

21-14169-AJC Notice will be mailed to: 

Synchrony Bank 

PRA Receivables Management, LLC 

PO Box 41021 

Norfolk, VA 23541 

Case 21-14169-PGH Doc 21 Filed 06/30/21 Page 3 of 3