Case: 09-13747 Doc: 20 Filed: 07/16/13 Page: 1 of 2
IN THE UNITED STATES BANKRUPTCY COURT
WESTERN DISTRICT OF OKLAHOMA
IN RE: )
GAYLON JAY TOLES )
CASE NO. 09-13747-NLJ
OBJECTION TO TRUSTEE’S MOTION TO DISMISS FOR FAILURE TO MAKE
REGULAR PAYMENTS AND APPLICATION FOR ATTORNEY COMPENSATION
COMES NOW, Gaylon Jay Toles, (hereinafter referred to as “Debtor”) by and through
her attorney of record, Dekovan L. Bowler of the Law Firm of Bowler & Associates P.C., and
hereby objects to the Chapter 13 Trustee’s Motion to Dismiss for Failure to Make Regular
Payments filed herein on July 15, 2013. In support of said objection the Debtor would state as
Debtor filed for relief under the provisions of Chapter 13 Bankruptcy on July 13,
Debtor’s Chapter 13 plan was confirmed on September 14, 2009.
Debtor is currently behind on her Chapter 13 plan payments due to a loss of
Debtor proposes to cure the missed payments by increasing the term of her plan
payments over the next six (6) months. In addition, the Debtor would request that
her attorney be awarded $350.00 for his fees and costs in resolving this matter.
Debtor further proposes that if the regular or cure payments over the next six (6)
months are not made by the last business day of each month the Chapter 13 Trustee
may present an order, ex parte dismissing this case with no further notice.
WHEREFORE premises considered, Debtor prays that this Court deny the Chapter 13
Trustee’s Motion to Dismiss and issue an Order allowing the Debtor to cure the missed Chapter 13
Case: 09-13747 Doc: 20 Filed: 07/16/13 Page: 2 of 2
plan payments over the next six (6) months and for any further relief the Debtor may be entitled to
according to bankruptcy law.
/s/ Dekovan L. Bowler
Dekovan L. Bowler, OBA #15193
BOWLER & ASSOCIATES P.C.
8333 SE 15th St.
Midwest City, OK 73110
(405) 733-3000 Office
ATTORNEY FOR THE DEBTOR
CERTIFICATE OF MAILING
This is to certify that on the 16th day of July, 2013, a true and correct copy of the above and
foregoing Objection to Trustee’s Motion to Dismiss for Failure to Make Payments was mailed to:
John T. Hardeman, Chapter 13 Trustee, P.O. Box 1948, Oklahoma City, OK 73101.
/s/ Dekovan L Bowler
Dekovan L. Bowler