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Jessica Sabo, #026360
Staff Attorney
101 N. 1 Ave., #1775
Phoenix, AZ 85003
Telephone (602) 277-3776
Fax No. (602) 277-4103
[email protected]

IN THE UNITED STATES BANKRUPTCY COURT

FOR THE DISTRICT OF ARIZONA

In re:
LUIS VARONA,
Debtor.

In Proceedings Under Chapter 13
Case No. 2:13-bk-13424-EWH

SUPPLEMENT TO TRUSTEE’S MOTION
TO DISMISS AND REQUEST FOR
DISMISSAL WITH PREJUDICE
(Docket #28)

This matter comes before the Court on the Trustee's Motion to Dismiss With Prejudice
(Docket # 28). Debtor's scheduled Section 341 Meeting of Creditors took place on September 18,
2013, at approximately 9:00 a.m. At the Hearing, the Debtor testified, under oath, to a number of
addtional facts:

1. Debtor's Nephew, the former Luis Rene Velasco ( now, Luis ReneVarona, Case #'s:4:09-
bk-20446; 4:09-bk-23695; 2:13-03451) opened up a P.O. Box in Phoenix, Arizona for the pupose
of changing venue in the Debtors present case, to Maricopa County. The Debtor has at all times,
lived in Nogales, Arizona.

2. The Debtor's former Bankruptcy Case, #4:10-bk-37691, was filed, and schedules and

statements were signed, by the Nephew.

3. Other than the Debtor's signature on the present Petition, the Nephew and some, still

unkown third party, signed and filed the documents in the present case.

4. The Debtor (through his Nephew) lists four properties on his schedules but lists no income
from those properties. It is still unclear, who owns all four properties. The Debtor testified that he
himself owned all four and three of them are rentals.

5. In the prior case of the Debtor, 4:10-bk-37691, filed by the Nephew, there were several
1/100th % interests in properties listed on amended schedule "A's". The Debtor admitted to Trustee's

Case 2:13-bk-13424-EWH Doc 31 Filed 09/19/13 Entered 09/19/13 14:45:59 Desc

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Counsel, that the Nephew had worked with disbarred attorney Richard Berry to both file Debtor's
previous case and to obtain the 1/100th % interests for purposes of forestalling foreclosures on those
properties. The 1/100th % interests are not listed on the present case however we believe those
interests still remain.

Dated [see signature block]

_______________________________________
Jessica Sabo, Esq.
Staff Attorney for Edward J. Maney, Trustee

Luis Varona
P.O. Box 32842
Phoenix, AZ 85064
Luis Varona
727 W. Lakeview
Nogales, AZ 85621
Luis Varona
515-19 Fifth Ave.
Tucson, AZ 85701
Luis Varona
2727 N. Green Pl.
Nogales, AZ 85621
Guy Roll. Esq.
2151 East Broadway Road, Suite 216
Tempe, AZ 85282

Luis Varona
4425 Berenice Av.
Los Angeles, CA 90031

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Case 2:13-bk-13424-EWH Doc 31 Filed 09/19/13 Entered 09/19/13 14:45:59 Desc

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CERTIFICATE OF MAILING

Jessica Sabo, Staff Attorney to Edward J. Maney CHAPTER 13 TRUSTEE (hereinafter
the “Trustee”), hereby certifies that a copies of the Notice were mailed on September 19, 2013,
to the following parties:
Luis Varona
P.O. Box 32842
Phoenix, AZ 85064

Luis Varona
727 W. Lakeview
Nogales, AZ 85621

Luis Varona
515-19 Fifth Ave.
Tucson, AZ 85701

Luis Varona
2727 N. Green Place
Nogales, AZ 85621

Luis Varona
4425 Berenice Av.
Los Angeles, CA 90031

Guy Roll, Esq.
2151 East Broadway Road
Suite 216
Tempe, AZ 85282

Dated: See Electronic Signature:



EDWARD J. MANEY,
CHAPTER 13 TRUSTEE

Jessica Sabo. Esq. #026360
Staff Attorney

Case 2:13-bk-13424-EWH Doc 31 Filed 09/19/13 Entered 09/19/13 14:45:59 Desc

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