Looking for sample Motion to allow creditor to file 523

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Thanks.
Holly Roark
Certified Bankruptcy Specialist*
holly@roarklawoffices.com **primary email address**
www.roarklawoffices.com
Central District of California
Consumer Bankruptcy Attorney
1875 Century Park East, Suite 600
Los Angeles, CA 90067
T (310) 553-2600
F (310) 553-2601
*By State Bar of California Board of Legal Specialization
**For a quicker response, email me at holly@roarklawoffices.com.
I only use gmail for my listservs, and am likely to miss private emails
directed to my gmail account.**
On Sat, May 11, 2013 at 10:50 AM, Stella Havkin wrote:
> **
>
>
> Just file. The debt is not discharged because of 523(c).
>
>
> Sent from my Stella Havkin's IPhone
>
> On May 11, 2013, at 10:14 AM, Holly Roark wrote:
>
>
>
> Creditor sued debtor in state court and has a fraud cause of action.
> Creditor never found out about the BK until after the debtor's discharge.
> He did not receive actual notice, constructive notice, or any type of
> notice. The case was reopened by the trustee because the debtor was hiding
> assets. Creditor will not be able to recover its full claim from these
> assets and wants to file a 523 against the debtor and also continue with
> the state court case.
> Can I just file the 523 AP or do I need to also file a Motion for leave
> to file it or some other kind of motion which would show the basis for why
> the former deadline should not apply to this creditor?
> Does anyone have a sample? Thank you.
>
>
>
> Holly Roark
> Certified Bankruptcy Specialist*
> holly@roarklawoffices.com **primary email address**
> www.roarklawoffices.com
> Central District of California
> Consumer Bankruptcy Attorney
> 1875 Century Park East, Suite 600
> Los Angeles, CA 90067
> T (310) 553-2600
> F (310) 553-2601
>
> *By State Bar of California Board of Legal Specialization
>
>
> **For a quicker response, email me at holly@roarklawoffices.com.
> I only use gmail for my listservs, and am likely to miss private emails
> directed to my gmail account.**
>
>
>
>
Thanks.Holly RoarkCertified Bankruptcy Specialist*
holly@roarklawoffices.com**primary email address**
www.roarklawoffices.com
Central District of California
Consumer Bankruptcy Attorney
1875 Century Park East, Suite 600
Los Angeles, CA 90067
T (310) 553-2600
F (310) 553-2601
*By State Bar of California Board of Legal
Specialization
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