Central District Consumer Bankruptcy Attorney's Association

Thanks Maria! I have done all that. I guess it couldn't hurt to file the motion as well...
MARIA TAM wrote: I will handle it differently. I think all you have to do is just call your client six or seven times at different work, cell and home phone numbers and leave messages. Also fax and send a letter reminding them that they must provide you with the info immediately or else case will be dismissed with 180 day bar from refiling. And once the case is dismissed, the automatic stay will be lifted. If the client does not do his job, all you have to do is tell him the consequences. Make sure you keep track of the day and time that you have called. And make sure that there is proof for your letter. I think by doing the above, you have fully performed your duty.
On 1/31/08, Henry M. Toles wrote: Attached is a Motion for an Extension that I used in one of my Chapter 11's. Just modify it to fit your need. If you do not file the extension motion, the case will be dismissed with a bar to refilling. This is the reason I hate emergency petitions (clients that don't follow through).

Hank Toles

PS: It is an old motion, but it is bullet proof). Leave off the trustee approval pages.

Henry M. Toles, J.D., M.B.A.
Henry M. Toles, A Law Corporation
11746 Goshen Avenue, No. 1
Los Angeles, California 90049-6113
Telephone: (310) 479-1400
Facsimile: (310) 575-0343
E-Mail: hmt@toles.org
Member National Association of Consumer Bankruptcy Attorneys (NACBA)
We are a federally designated Debt Relief Agency under the United States
Bankruptcy Laws. We assist people with finding solutions to their debt
problems, including, where appropriate, assisting them with the filing
of petitions for relief under the United States Bankruptcy Code.
This does not constitute an electronic signature.
This message contains confiidential information which may also be privileged. Unless you are the intended recipient (or authorized to receive for the intended recipient) you may not copy, use or distribute the information contained in this message.
-----Original Message-----
Sent: Thursday, January 31, 2008 12:52
To: CDCBAA
Subject: [cdcbaa] Motion to extend time to file additional schedules
Hello All-

Do I have an obligation to file a motion to extend time to file schedules (filed emergency to stop a foreclosure) if the client doesn't show up to TWO meetings scheduled to sign docs? I don't even have all the information I requested to complete the schedules.

Is there a mandatory form for this type of motion? I couldn't find it on the court's website. Your input is appreciated.

Thanks.

Susana B. Tolchard, Esq.
LAW OFFICES OF SUSANA B. TOLCHARD & ASSOCIATES
23734 Valencia Blvd., Suite 304
Valencia, CA 91355
Telephone: (661) 287-9986
Facsimile: (661) 287-9662

Member National Association of Consumer Bankruptcy Attorneys (NACBA)

We are a federally designated Debt Relief Agency under the United States
Bankruptcy Laws. We assist people with finding solutions to their debt
problems, including, where appropriate, assisting them with the filing
of petitions for relief under the United States Bankruptcy Code.
This does not constitute an electronic signature.
This message contains confidential information which may also be
privileged. Unless you are the intended recipient (or authorized to receive
for the intended recipient) you may not copy, use or distribute the
information contained in this message.



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Thanks Maria! I have done all that. I guess it couldn't hurt to file the motion as well...MARIA TAM <TAMLAWOFFICE@GMAIL.COM> wrote: I will handle it differently. I think all you have to do is just call your client six or seven times at different work, cell and home phone numbers and leave messages. Also fax and send a letter reminding them that they must provide you with the info immediately or else case will be dismissed with 180 day bar from refiling. And once the case is dismissed, the automatic stay will be

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Thanks Hank!

Susana
"Henry M. Toles" wrote:
Attached is a Motion for an Extension that I used in one of my Chapter 11's. Just modify it to fit your need. If you do not file the extension motion, the case will be dismissed with a bar to refilling. This is the reason I hate emergency petitions (clients that don't follow through).

Hank Toles

PS: It is an old motion, but it is bullet proof). Leave off the trustee approval pages.

Henry M. Toles, J.D., M.B.A.
Henry M. Toles, A Law Corporation
11746 Goshen Avenue, No. 1
Los Angeles, California 90049-6113
Telephone: (310) 479-1400
Facsimile: (310) 575-0343
E-Mail: hmt@toles.org
Member National Association of Consumer Bankruptcy Attorneys (NACBA)
We are a federally designated Debt Relief Agency under the United States
Bankruptcy Laws. We assist people with finding solutions to their debt
problems, including, where appropriate, assisting them with the filing
of petitions for relief under the United States Bankruptcy Code.
This does not constitute an electronic signature.
This message contains confiidential information which may also be privileged. Unless you are the intended recipient (or authorized to receive for the intended recipient) you may not copy, use or distribute the information contained in this message.
-----Original Message-----
Sent: Thursday, January 31, 2008 12:52
To: CDCBAA
Subject: [cdcbaa] Motion to extend time to file additional schedules
Hello All-

Do I have an obligation to file a motion to extend time to file schedules (filed emergency to stop a foreclosure) if the client doesn't show up to TWO meetings scheduled to sign docs? I don't even have all the information I requested to complete the schedules.

Is there a mandatory form for this type of motion? I couldn't find it on the court's website. Your input is appreciated.

Thanks.

Susana B. Tolchard, Esq.
LAW OFFICES OF SUSANA B. TOLCHARD & ASSOCIATES
23734 Valencia Blvd., Suite 304
Valencia, CA 91355
Telephone: (661) 287-9986
Facsimile: (661) 287-9662

Member National Association of Consumer Bankruptcy Attorneys (NACBA)

We are a federally designated Debt Relief Agency under the United States
Bankruptcy Laws. We assist people with finding solutions to their debt
problems, including, where appropriate, assisting them with the filing
of petitions for relief under the United States Bankruptcy Code.
This does not constitute an electronic signature.
This message contains confidential information which may also be
privileged. Unless you are the intended recipient (or authorized to receive
for the intended recipient) you may not copy, use or distribute the
information contained in this message.



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I really do not disagree with what Maria is advising. I attached the Motion
in case you wish to file one. I thoroughly dislike being put in this
position by clients. I also do not like emergency petitions because of it.
Hank
Henry M. Toles, J.D., M.B.A.
Henry M. Toles, A Law Corporation
11746 Goshen Avenue, No. 1
Los Angeles, California 90049-6113
Telephone: (310) 479-1400
Facsimile: (310) 575-0343
E-Mail: hmt@toles.org
Member National Association of Consumer Bankruptcy Attorneys (NACBA)
We are a federally designated Debt Relief Agency under the United States
Bankruptcy Laws. We assist people with finding solutions to their debt
problems, including, where appropriate, assisting them with the filing
of petitions for relief under the United States Bankruptcy Code.
This does not constitute an electronic signature.
This message contains confiidential information which may also be
privileged. Unless you are the intended recipient (or authorized to receive
for the intended recipient) you may not copy, use or distribute the
information contained in this message.
-----Original Message-----
MARIA TAM
Sent: Thursday, January 31, 2008 13:29
To: cdcbaa@yahoogroups.com
Subject: Re: [cdcbaa] Motion to extend time to file additional schedules
I will handle it differently. I think all you have to do is just call
your client six or seven times at different work, cell and home phone
numbers and leave messages. Also fax and send a letter reminding them that
they must provide you with the info immediately or else case will be
dismissed with 180 day bar from refiling. And once the case is dismissed,
the automatic stay will be lifted. If the client does not do his job, all
you have to do is tell him the consequences. Make sure you keep track of
the day and time that you have called. And make sure that there is proof
for your letter. I think by doing the above, you have fully performed your
duty.
On 1/31/08, Henry M. Toles wrote:
Attached is a Motion for an Extension that I used in one of my Chapter
11's. Just modify it to fit your need. If you do not file the extension
motion, the case will be dismissed with a bar to refilling. This is the
reason I hate emergency petitions (clients that don't follow through).
Hank Toles
PS: It is an old motion, but it is bullet proof). Leave off the
trustee approval pages.
Henry M. Toles, J.D., M.B.A.
Henry M. Toles, A Law Corporation
11746 Goshen Avenue, No. 1
Los Angeles, California 90049-6113
Telephone: (310) 479-1400
Facsimile: (310) 575-0343
E-Mail: hmt@toles.org
Member National Association of Consumer Bankruptcy Attorneys (NACBA)
We are a federally designated Debt Relief Agency under the United States
Bankruptcy Laws. We assist people with finding solutions to their debt
problems, including, where appropriate, assisting them with the filing
of petitions for relief under the United States Bankruptcy Code.
This does not constitute an electronic signature.
This message contains confiidential information which may also be
privileged. Unless you are the intended recipient (or authorized to receive
for the intended recipient) you may not copy, use or distribute the
information contained in this message.
-----Original Message-----
Of Susana Tolchard
Sent: Thursday, January 31, 2008 12:52
To: CDCBAA
Subject: [cdcbaa] Motion to extend time to file additional schedules
Hello All-
Do I have an obligation to file a motion to extend time to file
schedules (filed emergency to stop a foreclosure) if the client doesn't show
up to TWO meetings scheduled to sign docs? I don't even have all the
information I requested to complete the schedules.
Is there a mandatory form for this type of motion? I couldn't find it
on the court's website. Your input is appreciated.
Thanks.
Susana B. Tolchard, Esq.
LAW OFFICES OF SUSANA B. TOLCHARD & ASSOCIATES
23734 Valencia Blvd., Suite 304
Valencia, CA 91355
Telephone: (661) 287-9986
Facsimile: (661) 287-9662
Member National Association of Consumer Bankruptcy Attorneys (NACBA)
We are a federally designated Debt Relief Agency under the United
States
Bankruptcy Laws. We assist people with finding solutions to their debt
problems, including, where appropriate, assisting them with the filing
of petitions for relief under the United States Bankruptcy Code.
This does not constitute an electronic signature.
This message contains confidential information which may also be
privileged. Unless you are the intended recipient (or authorized to
receive
for the intended recipient) you may not copy, use or distribute the
information contained in this message.
Never miss a thing. Make Yahoo your homepage.

The post was migrated from Yahoo.

I will handle it differently. I think all you have to do is just call your
client six or seven times at different work, cell and home phone numbers and
leave messages. Also fax and send a letter reminding them that they must
provide you with the info immediately or else case will be dismissed with
180 day bar from refiling. And once the case is dismissed, the automatic
stay will be lifted. If the client does not do his job, all you have to do
is tell him the consequences. Make sure you keep track of the day and time
that you have called. And make sure that there is proof for your letter. I
think by doing the above, you have fully performed your duty.
On 1/31/08, Henry M. Toles wrote:
>
> Attached is a Motion for an Extension that I used in one of my Chapter
> 11's. Just modify it to fit your need. If you do not file the extension
> motion, the case will be dismissed with a bar to refilling. This is the
> reason I hate emergency petitions (clients that don't follow through).
>
> Hank Toles
>
> PS: It is an old motion, but it is bullet proof). Leave off the trustee
> approval pages.
>
>
> Henry M. Toles, J.D., M.B.A.
> Henry M. Toles, A Law Corporation
> 11746 Goshen Avenue, No. 1
> Los Angeles, California 90049-6113
> Telephone: (310) 479-1400
> Facsimile: (310) 575-0343
> E-Mail: hmt@toles.org
>
> Member National Association of Consumer Bankruptcy Attorneys (NACBA)
>
> We are a federally designated Debt Relief Agency under the United States
> Bankruptcy Laws. We assist people with finding solutions to their debt
> problems, including, where appropriate, assisting them with the filing
> of petitions for relief under the United States Bankruptcy Code.
>
> This does not constitute an electronic signature.
>
> This message contains confiidential information which may also be
> privileged. Unless you are the intended recipient (or authorized to receive
> for the intended recipient) you may not copy, use or distribute the
> information contained in this message.
>
> -----Original Message-----
> *From:* cdcbaa@yahoogroups.com [mailto:cdcbaa@yahoogroups.com]*On Behalf
> Of *Susana Tolchard
> *Sent:* Thursday, January 31, 2008 12:52
> *To:* CDCBAA
> *Subject:* [cdcbaa] Motion to extend time to file additional schedules
>
> Hello All-
>
> Do I have an obligation to file a motion to extend time to file schedules
> (filed emergency to stop a foreclosure) if the client doesn't show up to TWO
> meetings scheduled to sign docs? I don't even have all the information I
> requested to complete the schedules.
>
> Is there a mandatory form for this type of motion? I couldn't find it on
> the court's website. Your input is appreciated.
>
> Thanks.
>
> Susana B. Tolchard, Esq.
> LAW OFFICES OF SUSANA B. TOLCHARD & ASSOCIATES
> 23734 Valencia Blvd., Suite 304
> Valencia, CA 91355
> Telephone: (661) 287-9986
> Facsimile: (661) 287-9662
>
> Member National Association of Consumer Bankruptcy Attorneys (NACBA)
>
> We are a federally designated Debt Relief Agency under the United States
> Bankruptcy Laws. We assist people with finding solutions to their debt
> problems, including, where appropriate, assisting them with the filing
> of petitions for relief under the United States Bankruptcy Code.
> This does not constitute an electronic signature.
> This message contains confidential information which may also be
> privileged. Unless you are the intended recipient (or authorized to
> receive
> for the intended recipient) you may not copy, use or distribute the
> information contained in this message.
>
>
>
> ------------------------------
> Never miss a thing. Make Yahoo your homepage.
>
>
>
>
I will handle it differently. I think all you have to do is just call your client six or seven times at different work, cell and home phone numbers and leave messages. Also fax and send a letter reminding them that they must provide you with the info immediately or else case will be dismissed with 180 day bar from refiling. And once the case is dismissed, the automatic stay will be lifted. If the client does not do his job, all you have to do is tell him the consequences. Make sure you keep track of the day and time that you have called. And make sure that there is proof for your letter. I think by doing the above, you have fully performed your duty.


On 1/31/08, Henry M. Toles <hmt@toles.org> wrote:
Attached is a Motion for an Extension that I used in one of my Chapter 11's. Just modify it to fit your need. If you do not file the extension motion, the case will be dismissed with a bar to refilling. This is the reason I hate emergency petitions (clients that don't follow through).

Hank Toles

PS: It is an old motion, but it is bullet proof). Leave off the trustee approval pages.

Henry M. Toles, J.D., M.B.A.Henry M. Toles, A Law Corporation11746 Goshen Avenue, No. 1Los Angeles, California 90049-6113Telephone: (310) 479-1400Facsimile: (310) 575-0343E-Mail: hmt@toles.org
Member National Association of Consumer Bankruptcy Attorneys (NACBA)We are a federally designated Debt Relief Agency under the United StatesBankruptcy Laws. We assist people with finding solutions to their debt
problems, including, where appropriate, assisting them with the filingof petitions for relief under the United States Bankruptcy Code.This does not constitute an electronic signature.This message contains confiidential information which may also be privileged. Unless you are the intended recipient (or authorized to receive for the intended recipient) you may not copy, use or distribute the information contained in this message.
-----Original Message-----From: cdcbaa@yahoogroups.com [mailto:cdcbaa@yahoogroups.com]On Behalf Of Susana Tolchard
Sent: Thursday, January 31, 2008 12:52To: CDCBAASubject: [cdcbaa] Motion to extend time to file additional schedules
Hello All-

Do I have an obligation to file a motion to extend time to file schedules (filed emergency to stop a foreclosure) if the client doesn't show up to TWO meetings scheduled to sign docs? I don't even have all the information I requested to complete the schedules.

Is there a mandatory form for this type of motion? I couldn't find it on the court's website. Your input is appreciated.

Thanks.

Susana B. Tolchard, Esq.LAW OFFICES OF SUSANA B. TOLCHARD & ASSOCIATES23734 Valencia Blvd., Suite 304Valencia, CA 91355Telephone: (661) 287-9986Facsimile: (661) 287-9662

Member National Association of Consumer Bankruptcy Attorneys (NACBA)

We are a federally designated Debt Relief Agency under the United StatesBankruptcy Laws. We assist people with finding solutions to their debtproblems, including, where appropriate, assisting them with the filing
of petitions for relief under the United States Bankruptcy Code.
This does not constitute an electronic signature.
This message contains confidential information which may also beprivileged. Unless you are the intended recipient (or authorized to receivefor the intended recipient) you may not copy, use or distribute the
information contained in this message.


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The post was migrated from Yahoo.

Attached is a Motion for an Extension that I used in one of my Chapter 11's.
Just modify it to fit your need. If you do not file the extension motion,
the case will be dismissed with a bar to refilling. This is the reason I
hate emergency petitions (clients that don't follow through).
Hank Toles
PS: It is an old motion, but it is bullet proof). Leave off the trustee
approval pages.
Henry M. Toles, J.D., M.B.A.
Henry M. Toles, A Law Corporation
11746 Goshen Avenue, No. 1
Los Angeles, California 90049-6113
Telephone: (310) 479-1400
Facsimile: (310) 575-0343
E-Mail: hmt@toles.org
Member National Association of Consumer Bankruptcy Attorneys (NACBA)
We are a federally designated Debt Relief Agency under the United States
Bankruptcy Laws. We assist people with finding solutions to their debt
problems, including, where appropriate, assisting them with the filing
of petitions for relief under the United States Bankruptcy Code.
This does not constitute an electronic signature.
This message contains confiidential information which may also be
privileged. Unless you are the intended recipient (or authorized to receive
for the intended recipient) you may not copy, use or distribute the
information contained in this message.
-----Original Message-----
Susana Tolchard
Sent: Thursday, January 31, 2008 12:52
To: CDCBAA
Subject: [cdcbaa] Motion to extend time to file additional schedules
Hello All-
Do I have an obligation to file a motion to extend time to file schedules
(filed emergency to stop a foreclosure) if the client doesn't show up to TWO
meetings scheduled to sign docs? I don't even have all the information I
requested to complete the schedules.
Is there a mandatory form for this type of motion? I couldn't find it on
the court's website. Your input is appreciated.
Thanks.
Susana B. Tolchard, Esq.
LAW OFFICES OF SUSANA B. TOLCHARD & ASSOCIATES
23734 Valencia Blvd., Suite 304
Valencia, CA 91355
Telephone: (661) 287-9986
Facsimile: (661) 287-9662
Member National Association of Consumer Bankruptcy Attorneys (NACBA)
We are a federally designated Debt Relief Agency under the United States
Bankruptcy Laws. We assist people with finding solutions to their debt
problems, including, where appropriate, assisting them with the filing
of petitions for relief under the United States Bankruptcy Code.
This does not constitute an electronic signature.
This message contains confidential information which may also be
privileged. Unless you are the intended recipient (or authorized to
receive
for the intended recipient) you may not copy, use or distribute the
information contained in this message.
Never miss a thing. Make Yahoo your homepage.

The post was migrated from Yahoo.

Hello All-

Do I have an obligation to file a motion to extend time to file schedules (filed emergency to stop a foreclosure) if the client doesn't show up to TWO meetings scheduled to sign docs? I don't even have all the information I requested to complete the schedules.

Is there a mandatory form for this type of motion? I couldn't find it on the court's website. Your input is appreciated.

Thanks.

Susana B. Tolchard, Esq.
LAW OFFICES OF SUSANA B. TOLCHARD & ASSOCIATES
23734 Valencia Blvd., Suite 304
Valencia, CA 91355
Telephone: (661) 287-9986
Facsimile: (661) 287-9662

Member National Association of Consumer Bankruptcy Attorneys (NACBA)

We are a federally designated Debt Relief Agency under the United States
Bankruptcy Laws. We assist people with finding solutions to their debt
problems, including, where appropriate, assisting them with the filing
of petitions for relief under the United States Bankruptcy Code.
This does not constitute an electronic signature.
This message contains confidential information which may also be
privileged. Unless you are the intended recipient (or authorized to receive
for the intended recipient) you may not copy, use or distribute the
information contained in this message.
Never miss a thing. Make Yahoo your homepage.
Hello All- Do I have an obligation to file a motion to extend time to file schedules (filed emergency to stop a foreclosure) if the client doesn't show up to TWO meetings scheduled to sign docs? I don't even have all the information I requested to complete the schedules. Is there a mandatory form for this type of motion? I couldn't find it on the court's website. Your input is appreciated. Thanks. Susana B. Tolchard, Esq.LAW OFFICES OF SUSANA B. TOLCHARD & ASSOCIATES23734 Valencia Blvd., Suite 304Valencia, CA 91355Telephone: (661) 287-9986Facsimile: (661) 287-9662 Member National Association of Consumer Bankruptcy Attorneys (NACBA) We are a federally designated Debt Relief Agency under the United StatesBankruptcy Laws. We assist people with finding solutions
to their debtproblems, including, where appropriate, assisting them with the filingof petitions for relief under the United States Bankruptcy Code. This does not constitute an electronic signature. This message contains confidential information which may also beprivileged. Unless you are the intended recipient (or authorized to receivefor the intended recipient) you may not copy, use or distribute theinformation contained in this message.
Never miss a thing. Make Yahoo your homepage.

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