23-43977-elm13, Motion to Continue Automatic Stay Page 1

NORRED LAW, PLLC

Clayton L. Everett, State Bar No. 24065212

515 E. Border Street | Arlington, Texas 76010

Telephone: (817) 704-3984 | clayton@norredlaw.com

Attorney for Debtor

UNITED STATES BANKRUPTCY COURT 

NORTHERN DISTRICT OF TEXAS

FORT WORTH DIVISION

In re:

Marcos Gonzalez-Lopez,

Debtor

Case No. 23-43977-elm

Chapter 13

MOTION FOR CONTINUATION OF AUTOMATIC STAY

TO THE HONORABLE EDWARD L. MORRIS, UNITED STATES BANKRUPTCY JUDGE:

COMES NOW, Marcos Gonzalez-Lopez (“Debtor”), and files this Motion for 

Continuation of Automatic Stay pursuant to 11 U.S.C. § 362(c)(3)(B), for an order continuing the 

automatic stay provided under §362(a) as to all creditors and therefore would respectfully show 

the Court as follows:

1. The Debtor filed a petition under chapter 13 on December 29, 2023.

2. The Debtor previously filed chapter 13 Case No. 19-41638-btr13 which was 

dismissed on April 19, 2023. This case was dismissed for failure to make plan payments timely. 

3. Debtor will be able to sustain a chapter 13 bankruptcy payment plan with his new 

chapter 13 filing because expects to maintain or improve his current income and possibly lower 

his monthly expenses. 

4. The petition in this case has been filed in good faith. The Debtor believes that the 

chapter 13 plan he has submitted will be confirmed and that he will be able to fully perform under 

the terms of the plan. A copy of the proposed plan is attached as Exhibit 1.

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5. The Debtor’s prior chapter 13 case, dismissed on April 19, 2023, was the only 

previous case by the Debtor that was pending during the preceding year. 

6. The Debtor’s prior chapter 13 case was not dismissed because the Debtor failed to 

file or amend his petition or any required documents, or to provide adequate protection payments 

ordered by the court.

7. The Debtor’s prior chapter 13 case 19-41638-btr13 was not dismissed at a time 

when there had been a motion for relief that was pending before the court or resolved with an order 

terminating, conditioning, or limiting the stay. 

8. Debtor will ask for an expedited hearing to be conducted on this motion before 

January 28, 2024. The automatic stay in this case terminates by operation of 11 U.S.C. § 

362(c)(3)(A) on January 28, 2024. Once a hearing is set by the Court, Debtor will promptly notify 

the parties of the hearing date and time. 

WHEREFORE, the Debtor requests that this Court continue the automatic stay under 

§362(a) as to all creditors for the duration of this chapter 13 proceeding, or until such time as the 

stay is terminated under §362(c)(1) or (c)(2), or a motion for relief is granted under §362(d). 

Alternatively, the debtor requests that this Court issue an order pursuant to §362(j) confirming that 

the automatic stay provided under §362(a) will terminate under §362(c)(3) only as to actions taken 

against the debtor or property of the debtor, but not as to actions taken against property of the 

estate or actions not taken in relation to a debt. 

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Respectfully submitted:

By: /s/ Clayton L. Everett

Clayton L. Everett, State Bar No. 24065212

clayton@norredlaw.com

Norred Law, PLLC

515 E. Border St., Arlington, Texas 76010

O: (817) 704-3984; F: (817) 524-6686

Attorney for Debtor

CERTIFICATE OF SERVICE

I hereby certify that on January 3, 2024, a true and correct copy of the above motion 

shall be served via electronic means to all those parties receiving electronic services in this 

bankruptcy proceeding and upon the attached creditor matrix.

/s/ Clayton L. Everett

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