Dismissal pursuant to 349 - House going to foreclosure tomorrow?

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Need to file an emergency motion.
Dennis McGoldrick
350 S. Crenshaw Bl., #A207B
Torrance, CA 90503
On Feb 15, 2010, at 2:31 PM, R Grace Rodriguez wrote:
Client's Chapter 13 DISMISSAL in June of 2009 reads:
Pursuant to the court's findings and conclusions made at the confirmation hearing in this case,
IT IS ORDERED THAT:
(1) debtor's bankruptcy case is dismissed;
(2) the court retains jurisdiction on all issues arising under Bankruptcy Code Sections 110, 329 and 362; and
(3) pursuant to Bankruptcy Code Section 349, debtor is prohibited from filing any new bankruptcy petition unless:
(a) debtor files a motion to request permission to file a new bankruptcy case ("Motion"), and the Motion is supported
by admissible evidence; and
(b) the court grants the Motion.
Client's house going to foreclosure sale tomorrow morning. No time to get an order. If I file a bankruptcy to stop the sale in violation of this order with an emergency order requesting permission to file, is that going to get the debtor in trouble? Will I get in trouble?
Does anyone have a motion or exemplar?
R. Grace Rodriguez, Esq.
OFF: (818) 734-7223
CEL: (323) 304-5496
NO EX-PARTE NOTICE VIA VOICE MAIL OR EMAIL: I do not accept e-mail notice for ex parte Applications via voicemail or by email. You must comply with California Law and give notice to a person in my office during regular business hours.
CONFIDENTIALITY STATEMENT: This message contains privileged and confidential information and is intended only for the individual named. If you are not the intended recipient you should not disseminate, distribute, store, print, copy or deliver this message. Please notify the sender immediately by e-mail if you have received this e-mail by mistake and delete this e-mail from your system.
Need to file an emergency motion. Dennis McGoldrick350 S. Crenshaw Bl., #A207BTorrance, CA 90503On Feb 15, 2010, at 2:31 PM, R Grace Rodriguez <rgracelaw@gmail.com> wrote:

Client's Chapter 13 DISMISSAL in June of 2009 reads:Pursuant to the court's findings and conclusions made at the confirmation hearing in this case,IT IS ORDERED THAT:
(1) debtor's bankruptcy case is dismissed;(2) the court retains jurisdiction on all issues arising under Bankruptcy Code Sections 110, 329 and 362; and(3) pursuant to Bankruptcy Code Section 349, debtor is prohibited from filing any new bankruptcy petition unless:
(a) debtor files a motion to request permission to file a new bankruptcy case ("Motion"), and the Motion is supportedby admissible evidence; and(b) the court grants the Motion.Client's house going to foreclosure sale tomorrow morning. No time to get an order. If I file a bankruptcy to stop the sale in violation of this order with an emergency order requesting permission to file, is that going to get the debtor in trouble? Will I get in trouble?
Does anyone have a motion or exemplar?-- R. Grace Rodriguez, Esq.OFF: (818) 734-7223CEL: (323) 304-5496NO EX-PARTE NOTICE VIA VOICE MAIL OR EMAIL: I do not accept e-mail notice for ex parte Applications via voicemail or by email. You must comply with California Law and give notice to a person in my office during regular business hours.
CONFIDENTIALITY STATEMENT: This message contains privileged and confidential information and is intended only for the individual named. If you are not the intended recipient you should not disseminate, distribute, store, print, copy or deliver this message. Please notify the sender immediately by e-mail if you have received this e-mail by mistake and delete this e-mail from your system.

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Posts: 22904
Joined: Sun Oct 18, 2020 11:38 pm


Client's Chapter 13 DISMISSAL in June of 2009 reads:
*Pursuant to the court's findings and conclusions made at the confirmation
hearing in this case,
IT IS ORDERED THAT:
(1) debtor's bankruptcy case is dismissed;
(2) the court retains jurisdiction on all issues arising under Bankruptcy
Code Sections 110, 329 and 362; and
(3) pursuant to Bankruptcy Code Section 349, debtor is prohibited from
filing any new bankruptcy petition unless:
(a) debtor files a motion to request permission to file a new bankruptcy
case ("Motion"), and the Motion is supported
by admissible evidence; and
(b) the court grants the Motion.*
Client's house going to foreclosure sale tomorrow morning. No time to get
an order. If I file a bankruptcy to stop the sale in violation of this
order with an emergency order requesting permission to file, is that going
to get the debtor in trouble? Will I get in trouble?
Does anyone have a motion or exemplar?
R. Grace Rodriguez, Esq.
OFF: (818) 734-7223
CEL: (323) 304-5496
NO EX-PARTE NOTICE VIA VOICE MAIL OR EMAIL: I do not accept e-mail notice
for ex parte Applications via voicemail or by email. You must comply with
California Law and give notice to a person in my office during regular
business hours.
CONFIDENTIALITY STATEMENT: This message contains privileged and
confidential information and is intended only for the individual named. If
you are not the intended recipient you should not disseminate, distribute,
store, print, copy or deliver this message. Please notify the sender
immediately by e-mail if you have received this e-mail by mistake and delete
this e-mail from your system.
Client's Chapter 13 DISMISSAL in June of 2009 reads:Pursuant to the court's findings and conclusions made at the confirmation hearing in this case,IT IS ORDERED THAT:
(1) debtor's bankruptcy case is dismissed;(2) the court retains jurisdiction on all issues arising under Bankruptcy Code Sections 110, 329 and 362; and(3) pursuant to Bankruptcy Code Section 349, debtor is prohibited from filing any new bankruptcy petition unless:
(a) debtor files a motion to request permission to file a new bankruptcy case ("Motion"), and the Motion is supportedby admissible evidence; and(b) the court grants the Motion.Client's house going to foreclosure sale tomorrow morning. No time to get an order. If I file a bankruptcy to stop the sale in violation of this order with an emergency order requesting permission to file, is that going to get the debtor in trouble? Will I get in trouble?
Does anyone have a motion or exemplar?-- R. Grace Rodriguez, Esq.OFF: (818) 734-7223CEL: (323) 304-5496NO EX-PARTE NOTICE VIA VOICE MAIL OR EMAIL: I do not accept e-mail notice for ex parte Applications via voicemail or by email. You must comply with California Law and give notice to a person in my office during regular business hours.
CONFIDENTIALITY STATEMENT: This message contains privileged and confidential information and is intended only for the individual named. If you are not the intended recipient you should not disseminate, distribute, store, print, copy or deliver this message. Please notify the sender immediately by e-mail if you have received this e-mail by mistake and delete this e-mail from your system.

The post was migrated from Yahoo.
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