Andy Lopez and Deborah Lopez

Notice of Motion and Motion to Dismiss Both Debtors for Unreasonable Delay

Bankr. N.D. Ill.September 27, 2019

IN THE UNITED STATES BANKRUPTCY COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION In re: Andy Lopez Deborah Lopez Debtors Case No. 19-21197 Chapter 13 Judge: Pamela S. Hollis ) ) ) ) NOTICE OF MOTION AND CERTIFICATE OF SERVICE Andy Lopez Deborah Lopez 2113 Alpine Way Plainfield, IL 60586 DAVID C NELSON 53 W JACKSON BLVD #430 CHICAGO, IL 60604-3648 Please take notice that on October 04, 2019 at 11:30 am, a representative of this office shall appear before the Honorable Judge Pamela S. Hollis, at the Joliet City Hall, 150 West Jefferson Street, 2nd Floor, Joliet, IL 60432 and present the motion set forth below. Your rights may be affected. You should read these papers carefully and discuss them with your attorney, if you have one in this bankruptcy case. (If you do not have an attorney, you may wish to consult one.) I certify that this office caused a copy of this notice to be delivered to the above listed debtors by depositing it in the U.S. Mail at 801 Warrenville Road, Lisle, IL and to the debtor's attorney electronically via the Court's CM/ECF system on September 27, 2019. /s/ Dana Twombly FOR: Glenn Stearns, Chapter 13 Trustee MOTION TO DISMISS FOR UNREASONABLE DELAY Now comes Glenn Stearns, Chapter 13 Trustee, and requests dismissal of the above case pursuant to 11 U.S.C. Section 1307 (c) and in support thereof, states the following: 1. The Debtors filed a petition under Chapter 13 on Monday, July 29, 2019. 2. The Debtors have failed to: Provide proof of filing tax returns for 2018, 2017, 2016, 2015.a. Conclude the regularly scheduled Section 341 Creditor Meeting.b. Provide all required pay advices.c. 3. As a result, the Debtors have failed to comply with the Bankruptcy Code and have caused an unreasonable delay that is prejudicial to creditors. WHEREFORE, the Trustee prays this case be dismissed for cause pursuant to Section 1307 (c). Respectfully Submitted; /s/ Gerald Mylander FOR: Glenn Stearns, Chapter 13 Trustee Glenn Stearns, Chapter 13 Trustee 801 Warrenville Road, Suite 650 Lisle, IL 60532-4350 Case 19-21197 Doc 25 Filed 09/27/19 Entered 09/27/19 09:20:39 Desc Main Document Page 1 of 1