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 11878 ) 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 60085 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, 2011. /s/patrick J Hart Attorney for Debtor Patrick J. Hart 728 Florsheim Drive Libertyville, IL 60048 Phone: (847) 680-7240
Document Page 2 of 5 Trustee: Glenn B Stearns 4343 Commerce Court Suite 120 Lisle, Illinois 60532 Creditors: ACS P. O. Box 7051 Utica, NY 13504-7051 All Credit Lenders 474 N Greenbay Road Waukegan, IL 60085 American Collection Corp. 9191 Estes Court Schaumburg, IL 60193 American Medical Collection Agency 2269 South Saw Mill River Road Building 3 Elmsford, NY 10523 American Servicing Co. 3476 Stateview Blvd. Fort Mill, SC 29715 AmeriCash Loans 2107 Sheridan Road, # C Suite 302 Zion, IL 60099 ASC 7495 New Horizon Way Frederick, MD 21703 Check N Go c/o NCA P.O. Box 550 Hutchinson, KS 67504-0550 Codilis & Associates, P.C. 15W030 North Frontage Road Suite 100 Burr Ridge, IL 60527 Condell Medical Center 900 Garfield Avenue Libertyville, IL 60048 Cubs Food c/o National Recoveries 11000 Central Avenue Suite 100 Blaine, MN 55434-3845 Illinois Collection Services 3101 W. 95th Street Evergreen Park, IL 60805 Kenneth Margules, MD c/o Northern Illinois Collection P.O. Box 287 Waukegan, IL 60079 MCW Physician Pediatric c/o Med Health Financial Services P.O. Box 1996 Milwaukee, WI 53201 Med1 02 Patient First c/o Armor Systems 2322 N Greenbay Road Waukegan, IL 60085 Midwestern Reg. Medical Center Attn: Patient Accounts 2610 Sheridan Road Zion, IL 60099 North Shore Agency P.O. Box Westbury, NY 11590-8901 Northern Illinois Collection 1660 Yorkhouse P.O. Box 287 Waukegan, IL 60079 Oxmoor House c/o North Shore Agency P.O. Box 8901 Westbury, NY 11590-8901 Patient First c/o Armor Systems Corp., 2322 N. Green Bay Road Waukegan, IL 60087 Pediatric Radiology c/o Federated ADJ 7929 N. Port Washington Milwaukee, WI 53217-3135 Professional Account Services P.O. Box 188 Brentwood, TN 37024 Quest Diagnostics 1355 Mittel Blvd., Attn: Patient Billing Wood Dale, IL 60191-1024 TCF National Bank c/o Heller & Frisone 33 N. LaSalle, # 1200 Chicago, IL 60602-2603 Vista Imaging Assoc. c/o AR Resources P.O. Box 10336 Jacksonville, FL 32247-0336
Document Page 3 of 5 Vista Medical Center c/o Senex P.O. Box 6250 Madison, WI 53701 Vista Medical Center P.O. Box 504316 Saint Louis, MO 63150-4316
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 11878 ) 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, 2007. 3. 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
Document Page 5 of 5 Mercedes ML320 on credit. The price of the vehicle is $10,486.08. Debtors will make a $2,000.00 down payment and the balance will be paid in payments of $175.00 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 $8,486.08 with payments of $175.00 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 60048 Phone: 847 680-7240
Case 07-11878 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 www.adobe.com/products/acrobat/readstep2.html For further support, go to www.adobe.com/support/products/acrreader.html