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Russell D. Garrett, WSBA#18657 Chapter 7 Trustee 1499 SE Tech Center Place, Suite 380 Vancouver, W A 98683 Telephone: (360) 567-3909 Facsimile: (360) 567-3901

Hon. Paul B. Snyder Chapter: 7 Location: Federal Building, Vancouver, WA Hearing Date: December 3,2013 Hearing Time: 9:00 am Response Date: November 26,2013

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9 10 UNITED STATES BANKRUPTCY COURT WESTERN DISTRICT OF WASHINGTON AT TACOMA

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MARK A. LEONARD,

No. 13-43836-PBS OTICE OF HEARING AND MOTION XTEND TIME TO FILE COMPLAINT ETERMINE NONDISCHARGEABILITY DER 11 U.S.C. SS 523 AND 727 TO TO

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13 14 Debtor.

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PLEASE

TAKE NOTICE

that Russell D. Garrett, duly appointed

Chapter 7 to Determine

Trustee, has filed a Motion for Order to Extend Time to File Complaint Nondischargeability Under 11 U.S.c.

S 523

andll

U.S.C.

S 727.

The Motion will be

18 heard on December 3, 2013, at 9:00 a.m. before the Honorable Paul B. Snyder, and the

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clerk is requested 20 to note the motion to be heard that day and time. NOTIFIED that if you oppose the motion, you must file

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YOU ARE FURTHER your written response chambers,

with the Clerk of the Court, serve two copies on the Judge's and the United States Trustee's Office

and deliver copies to the undersigned 26,2013.

NOT LATER THAN NOVEMBER

Page 1- NOTICE OF HEARING AND MOTION TO EXTEND TIME TO FILE COMPLAINT TO DETERMINE NONDISCHARGEABILITY UNDER II US.C

ss 523 AND

727

JORDAN RAMIS, P.c. 1499 SE Tech Center Place, Suite 380 Vancouver, WA 98683 Telephone: 360-567-3900

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IF NO RESPONSE IS TIMELY FILED AND SERVED, the Court may in its own discretion, GRANT THE MOTION PRIOR TO THE HEARING WITHOUT FURTHER NOTICE and strike the hearing. NATURE OF THE MOTION Russell D. Garrett, Trustee, in this matter, moves the Court for an Order

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6 Extending the Deadline for Discharge to Determine Nondischargeability
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under 11 U.S.C.

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S 523 and 11 U.S.c. S 727. This Motion is based upon Fed.R.Bank.P 4004(b) and the
facts alleged herewith. MOTION This case was filed by the debtor on June 7, 2013. The debtor filed schedules and a statement of financial affairs.

13 Currently, the last day to object to the Debtor's discharge was and is scheduled 14 for November 6,2013 by order. The reason for the extension of time to file a complaint 15 16
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for denial of discharge or exception to discharge is that the trustee is still investigating potential assets of the estate and issues related to the debtor's disclosures in addition to the pending objection to exemption. The Trustee requested in open court in October that this order be extended to after the February hearing. Debtor's counsel consented to an extension on the record. The Court told all of the parties that the Court would grant the extension and to forward an order. Since then Mr. Brungardt has not responded to the form of order forwarded to him by the Trustee, which necessitates this motion. III

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**

523 AND 727

JORDAN RAM IS, P.c. 1499 SE Tech Center Place, Suite 380 Vancouver, W A 98683 Telephone: 360-567-3900

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WHEREFORE,

the Trustee requests the court extend the discharge

deadline

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days to February 20,2014.

CONCLUSION
For the foregoing reasons, Russell D. Garrett, Chapter 7 Trustee, requests this 6,2013 to February 20, 2014 for the debtor's or exception to

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Court to extend the time from November discharge discharge and deadline to file a complaint

for denial of discharge dischargeability

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in order to allow time to determine under 11 U.S.C.

S 523

and

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11 U.S.C. 9 10

S 727.
2013.

DATED this 5th day of November,

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523 AND 727

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CERTIFICATE OF SERVICE
I hereby certify that on the 5th day of November, 2013, I caused to be served the foregoing TRUSTEE'S MOTION TO EXTEND TIME TO FILE COMPLAINT TO DETERMINE NONDISCHARGEABILITY following: VIA ECF NOTICE: United States Trustee USTPREGIONI8.SE.ECT@usdoj.gov Robert C. Brungardt evelyn638@yahoo.com Debtor's Attorney UNDER 11 U.S.C.

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SS

523 AND 727 on the

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JORDAN RAMIS, P.e. 1499 SE Tech Center Place, Suite 380 Vancouver, W A 98683 Telephone: 360-567-3900

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9 In re 10

UNITED STATES BANKRUPTCY COURT FOR THE WESTERN DISTRICT OF WASHINGTON

No. 13-43836-PBS [PROPOSED] ORDER GRANTING TRUSTEE'S MOTION TO EXTEND TIME TO FILE COMPLAINT TO DETERMINE NONDISCHARGEABILITY UNDER 11 U.S.C. SS 523 AND 727

MARK A. LEONARD,

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Debtor.

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THIS MATTER Order Extending

came on before the Court on the Motion of the Chapter 7 Trustee for an to Determine the Trustee's Nondischargeability Under 11 U.S.C.

Time to File Complaint

SS

523 and 727. The Court having reviewed been no objection

Motion, finding good cause, there having

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filed to the motion, and the Court being fully advised in the premises; IT IS HEREBY ORDERED that the deadline for filing objections

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NOW, THEREFORE,

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III III III III

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TO EXTEND TIME TO FILE COMPLAINT TO DETERMINE NONDISCHARGEABILITY UNDER I I U.S.c. 99523 AND 727

JORDAN RAMIS PC 1499 SE Tech Center Place Suite 380 Vancouver, W A 98683 Telephone: 360-567-3900 Fax: 360-567-3901

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to discharge under 11 U.S.c. S 727 and exceptions to discharge pursuant to 11 U.S.C. S 523 are 2 3 4 5 6 7 8
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hereby extended to and including February 20, 2014. ///End ofOrder/// Presented by:

Russell D. Garrett, WSB #18657 Chapter 7 Trustee

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TO EXTEND TIME TO FILE COMPLAINT TO DETERMINE NONDISCHARGEABILITY UNDER I I U.S.c. 99 523 AND 727
JORDAN RAMIS PC 1499 SE Tech Center Place Suite 380 Vancouver, W A 98683 Telephone: 360-567-3900 Fax: 360-567-3901

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