United States Bankruptcy Court Northern District of Illinois Eastern Division

Transcription

1 Document Page 1 of 5 United States Bankruptcy Court Northern District of Illinois Eastern Division In Re: Shantal R and Alan K Taylor ) ) Case No Re: 07 B ) Judge: : A Benjamin Goldgar ) Debtor(s) ) To: See Attached Service List NOTICE OF MOTION PLEASE TAKE NOTICE that on August 26, 2011, at 9:00 a.m. or as soon thereafter as counsel may be heard, I shall appear before the Honorable A Benjamin Goldgar at The Lake County Branch Court, 301 Greenleaf, Park City, Illinois in Courtroom B, or before any other Bankruptcy Judge presiding in his stead, and then and there present the attached Motion to Allow Debtors to Incur Additional Debt and ask for a hearing instanter thereon. PROOF OF SERVICE I, the undersigned attorney, certify that I have served a copy of this Notice with attached Motion to Allow Debtors to Incur Additional Debt and Proposed Order by depositing same in a properly addressed envelope, postage prepaid, to each person to whom it is directed, in a U.S. mailbox in Libertyville, Illinois on or before the hour of 4:00 p.m. this 5 th day of August, /s/patrick J Hart Attorney for Debtor Patrick J. Hart 728 Florsheim Drive Libertyville, IL Phone: (847)

2 Document Page 2 of 5 Trustee: Glenn B Stearns 4343 Commerce Court Suite 120 Lisle, Illinois Creditors: ACS P. O. Box 7051 Utica, NY All Credit Lenders 474 N Greenbay Road Waukegan, IL American Collection Corp Estes Court Schaumburg, IL American Medical Collection Agency 2269 South Saw Mill River Road Building 3 Elmsford, NY American Servicing Co Stateview Blvd. Fort Mill, SC AmeriCash Loans 2107 Sheridan Road, # C Suite 302 Zion, IL ASC 7495 New Horizon Way Frederick, MD Check N Go c/o NCA P.O. Box 550 Hutchinson, KS Codilis & Associates, P.C. 15W030 North Frontage Road Suite 100 Burr Ridge, IL Condell Medical Center 900 Garfield Avenue Libertyville, IL Cubs Food c/o National Recoveries Central Avenue Suite 100 Blaine, MN Illinois Collection Services 3101 W. 95th Street Evergreen Park, IL Kenneth Margules, MD c/o Northern Illinois Collection P.O. Box 287 Waukegan, IL MCW Physician Pediatric c/o Med Health Financial Services P.O. Box 1996 Milwaukee, WI Med1 02 Patient First c/o Armor Systems 2322 N Greenbay Road Waukegan, IL Midwestern Reg. Medical Center Attn: Patient Accounts 2610 Sheridan Road Zion, IL North Shore Agency P.O. Box Westbury, NY Northern Illinois Collection 1660 Yorkhouse P.O. Box 287 Waukegan, IL Oxmoor House c/o North Shore Agency P.O. Box 8901 Westbury, NY Patient First c/o Armor Systems Corp., 2322 N. Green Bay Road Waukegan, IL Pediatric Radiology c/o Federated ADJ 7929 N. Port Washington Milwaukee, WI Professional Account Services P.O. Box 188 Brentwood, TN Quest Diagnostics 1355 Mittel Blvd., Attn: Patient Billing Wood Dale, IL TCF National Bank c/o Heller & Frisone 33 N. LaSalle, # 1200 Chicago, IL Vista Imaging Assoc. c/o AR Resources P.O. Box Jacksonville, FL

3 Document Page 3 of 5 Vista Medical Center c/o Senex P.O. Box 6250 Madison, WI Vista Medical Center P.O. Box Saint Louis, MO

4 Document Page 4 of 5 United States Bankruptcy Court Northern District of Illinois Eastern Division In Re: Shantal R and Alan K Taylor ) ) Case No Re: 07 B ) Chapter 13 ) Judge: : A Benjamin Goldgar MOTION TO ALLOW DEBTORS TO INCUR ADDITIONAL DEBT Shantal R and Alan K Taylor ( Debtors ), by and through their attorney, Patrick J. Hart, moves this Court for an Order to Incur Additional Debt. In support of this Motion the Debtor states the following: 1. Debtors commenced this case on July 3, 2007, by filing a Voluntary Petition for Relief under Chapter 13 of Title 11 of the United States Bankruptcy Code. 2. That plan was confirmed on October 26, On January 28, 2011 and order was entered modifying the plan and adjusting the payments over the remaining term of the plan. 4. That Debtors were the owner of a 1997 Chrysler Town & Country-V6 Wagon SX prior to and during the bankruptcy. 5. That said vehicle was destroyed by a fire on May 10, 2011 and classified as totaled by the Debtors insurer. 6. That Debtors now have only one vehicle and need a second vehicle because both Debtors are employed and each requires a vehicle to travel to and from work. 7. That Debtor has obtained an offer from Lake County Auto Sales to sell them a 2002

5 Document Page 5 of 5 Mercedes ML320 on credit. The price of the vehicle is $10, Debtors will make a $2, down payment and the balance will be paid in payments of $ every two weeks. A Copy of the Bill of Sale is attached. 8. That Debtors have filed a separate motion to request a modification of the Chapter 13 plan and such motion requests that the new payments reflect the new debt incurred. WHEREFORE, Debtors respectfully request that this Honorable Court grant an Order authorizing the Debtors to incur additional Debt in the approximate amount of $8, with payments of $ every two weeks. Respectfully submitted, Shantal R and Alan K Taylor By: /s/ Patrick J Hart Their attorney Patrick J Hart 728 Florsheim Drive Libertyville, IL Phone:

6 Case Doc 66-1 Filed 08/20/11 Entered 08/20/11 10:41:27 Desc Proposed Order Page 1 of 1 To view the full contents of this document, you need a later version of the PDF viewer. You can upgrade to the latest version of Adobe Reader from For further support, go to