You're viewing Docket Item 54 from the case Wanda Elois Daniel. View the full docket and case details.

Download this document:




Case 12-33766-KLP Doc 54 Filed 09/16/13 Entered 09/16/13 16:17:52 Desc Main

Document Page 1 of 3

IN THE UNITED STATES BANKRUPTCY COURT

EASTERN DISTRICT OF VIRGINIA

Richmond Division

Case No. 12-33766-KLP
Chapter 13




In re: Wanda Elois Daniel





Debtor’s Address: 105 East Leigh Street
Richmond, VA 23219


Last Four Digits of Debtor’s SSN: XXX-XX-3558





JOINT MOTION TO CONTINUE HEARING



COME NOW, Wanda Elois Daniel (the “Debtor”), by counsel, and Neighborhood

Housing Services of Richmond, Inc., (“NHSR”), by counsel, and state as follows:

1.

On February 26, 2013, NHSR filed an Amended Objection to the

Confirmation of Debtor’s Chapter 13 plan (the “Amended Objection to Confirmation”) in

the instant case.

2.

On May 23, 2013, Debtor filed an Objection to the Claim (the “Objection to

Claim”) filed by NHSR in the instant case.

3.

The Court scheduled an Evidentiary Hearing on the Amended Objection to

Confirmation, and the Objection to Claim, for September 25, 2013, at 2:00 p.m.

4.

Counsel jointly and respectfully request a continuance of the Evidentiary

Hearing until November 13, 2013, at 2:00 p.m.



Emily Connor Fort (VSB #83889)
Mark C. Leffler (VSB #40712)
Boleman Law Firm, P.C.
P. O. Box 11588
Richmond, VA 23230-1588
Telephone (804) 358-9900
Counsel for Debtor

Case 12-33766-KLP Doc 54 Filed 09/16/13 Entered 09/16/13 16:17:52 Desc Main

Document Page 2 of 3

5.

Counsel jointly represent that they have been and continue to be engaged

in discovery, and have communicated with each other in an effort to narrow or resolve

the issues. Counsel believe that additional time will allow the parties to conclude with

discovery and continue in efforts to reach a settlement.

WHEREFORE, Wanda Elois Daniel and NHSR, jointly request the Court grant

the instant Motion and continue the Evidentiary Hearing presently scheduled for

September 25, 2013, at 2:00 p.m. until November 13, 2013, at 2:00 p.m.

Wanda Elois Daniel

By Counsel:


/s/ Emily Connor Fort
Emily Connor Fort (VSB #83889)
Mark C. Leffler (VSB #40712)
Boleman Law Firm, P.C.
P. O. Box 11588
Richmond, Virginia 23230-1588
Telephone (804) 358-9900
Counsel for Debtor





Neighborhood Housing Services of Richmond, Inc.

By Counsel:


/s/ Emily Connor Fort on behalf of Alexander H. Ayers with permission via email
Alexander H. Ayers (VSB# 77826)
Counsel for Neighborhood Housing Services of Richmond, Inc.
Ayers & Stolte, PC
[email protected]
Via ECF




Case 12-33766-KLP Doc 54 Filed 09/16/13 Entered 09/16/13 16:17:52 Desc Main

Document Page 3 of 3

CERTIFICATE OF SERVICE

I hereby certify that on September 16, 2013, a copy of the foregoing Motion was



mailed, first class mail, postage prepaid, to Debtor, and served via the Court’s ECF
system to Alexander H. Ayers, Esquire, Carl M. Bates, Chapter 13 Trustee, and the
Office of the U.S. Trustee.





/s/ Emily Connor Fort
Counsel for Debtor