UNITED STATES BANKRUPTCY COURT

MIDDLE DISTRICT OF FLORIDA

JACKSONVILLE DIVISION

In re:

Debtor.
___________________________/
MOTION TO REINSTATE CASE AND BANKRUPTCY STAY
Debtors, by and through the undersigned counsel move this court for the entry of an order
reinstating their Chapter 13 case and the bankruptcy stay and in support thereof state:

1. On January 8, 2015, this Court dismissed the above case for Debtors failure to make
timely plan payments.
2. The Debtors were behind on plan payments in the amount of $3600.00 on December
2014.
3. At the time of the filing of the instant Motion there is a total amount of $13836.20 due to
bring the Debtors current on her plan payments.
4. The Debtor has the ability to bring the plan payments current and requests this Court
enter an order reinstating her Chapter 13 case and allowing them 60 days to bring the
5.

plan current.
The automatic stay has lapsed prior to the filing of the instant Motion. Debtors request
an Order Reinstating the stay under 11 U.S.C. 362.
WHEREFORE, Debtors pray that this court enter an order reinstating their chapter 13

case and the bankruptcy stay and awarding the Debtors any other relief that is just and proper.