Jason Sughrue 

State Bar No. 24048150 

ALLMAND LAW FIRM, P.L.L.C. 

860 Airport Freeway Suite 401 

Hurst, TX 76054 

214.265.0123 Phone 

214.265.1979 Fax 

ATTORNEY FOR DEBTORS 

IN THE UNITED STATES BANKRUPTCY COURT 

FOR THE NORTHERN DISTRICT OF TEXAS 

DALLAS DIVISION 

IN RE: § 

 § 

BRITTANY RENEE RANSOM § Case No. 23-30856-13 

 § 

 Debtors § Chapter 13 

 

MOTION TO IMPOSE THE AUTOMATIC STAY AFTER TWO PRIOR DISMISSALS 

WITHIN YEAR OF FILING 

TO THE HONORABLE JUDGE OF THIS COURT: 

 COME NOW Debtors, Brittany Renee Ransom, pursuant to 11 U.S.C. §362(c)(3)(B), 

requesting an order continuing the automatic stay provided under 11 U.S.C. §362(a) as to all 

creditors. In support of this motion, Debtor(s) state as follows: 

1. This Court has jurisdiction over this matter pursuant to 11 U.S.C. §105(a), 28 U.S.C. 

§157(b)(1), and 28 U.S.C. §1334. This matter constitutes a core proceeding as defined 

by 28 U.S.C. §157(b)(2). 

2. Debtors filed the current petition for relief under Chapter 13 on 04/29/2023. 

3. Within the twelve months prior to said filing date, Debtors were in an active Chapter 13 

case, number 23-30138. Said case dismissed on Feb. 21, 2023, for Debtor failed to file 

Schedules, Declaration of Electronic Filing and Statement of Financial Affairs. 

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4. Said case was not dismissed because the Debtor failed to (a) file or amend the petition or 

other documents as required, or (b) provide adequate protection as ordered by the Court. 

5. Debtors have no other cases pending within the twelve month period prior to 04/29/2023. 

6. Debtors filed one other bankruptcy case(s) in the last eight years, 22-32174. Said case 

was filed on Nov. 18, 2022 and dismissed on Dec. 29, 2022, for failing to file schedules 

and statement of financial affairs.. 

7. As of the date of dismissal of Debtors' prior case(s), the following §362(d) actions were 

either pending or resolved by terminating, conditioning, or limiting the stay. 

a) None. 

8. Debtors filed the pending case in good faith. A substantial change in the financial and 

personal affairs of the Debtor has occurred since the dismissal of the previous case. In 

addition to having her schedules on file, the Debtor has a new job in addition to her 

current employment and has sufficient income to make plan payments. 

9. Debtors will fully perform the terms of a confirmed plan in the pending case. 

10. This motion is not made for the purposes of delay. 

11. Debtor's counsel requests $200.00 for the prosecution of this Motion. 

 WHEREFORE, PREMISES CONSIDERED, Debtors Brittany Renee Ransom and 

respectfully request the Court continue the stay under 11 U.S.C. §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 from stay is granted under §362(d). 

 

Dated: May 3, 2023 

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 Respectfully Submitted, 

 ALLMAND LAW FIRM, P.L.L.C. 

 /s/ Jason Sughrue 

 Jason Sughrue 

 State Bar No. 24048150 

 ALLMAND LAW FIRM, P.L.L.C. 

 860 Airport Freeway Suite 401 

 Hurst, TX 76054 

214.265.0123 Phone 

214.265.1979 Fax 

 ATTORNEY FOR DEBTORS 

 

CERTIFICATE OF CONFERENCE 

The undersigned Debtors' Counsel hereby certifies a pre-filing conference was not held, 

because it was not possible to confer with all scheduled creditors, given the time constraint 

imposed by 11 U.S.C. §362(c)(3)(B), requiring a hearing be completed before the expiration of 

the thirty-day period after filing of the petition. It is presumed this motion is opposed. 

 

 By: /s/ Jason Sughrue 

 Jason Sughrue 

 State Bar No. 24048150 

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CERTIFICATE OF SERVICE 

 The undersigned hereby certifies that on May 3, 2023, a true and correct copy of the 

foregoing was served on all parties in interest below and on the attached mailing matrix. 

DEBTORS 

Brittany Renee Ransom 

166 Yale Ave 

Red Oak, TX 75154 

STANDING CHAPTER 13 TRUSTEE 

Tom Powers 

105 Decker Ct., 11th Flr., Ste. 1150 

Irving, Texas 75062 

U.S. TRUSTEE 

Rm. 976 

1100 Commerce Street 

Dallas, TX 75242 

U.S. ATTORNEY GENERAL 

Main Justice Building, Rm. 5111 

10th & Constitution Ave 

NW Washington D.C. 20530 

 

 By: /s/ Jason Sughrue 

 Jason Sughrue 

 State Bar No. 24048150 

 

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