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UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF MARYLAND

INRE: MONIQUE OLIVER

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Case No. 11-22071 TJC

Debtor
v. Merrill Cohen Trustee

Chapter 7

DEBTOR'S MOTION TO REINSTATE CHAPTER & PETITION COMES NOW, Monique Oliver, debtor through counsel, Jonathan Hoover and respectfully request that the Court reinstate debtor's Chapter 7 petition and as grounds state the following: 1. On or about June 12, 2011 Counsel's computer crashed after a virus infiltrated the operating system. 2. Counsel used this computer to file and store all of his bankruptcy filings as well as maintain important dates as it pertained to debtor's case. 3. Counsel had to install a new operating system and as result Counsel's data as well as calendar were deleted. 4. After Counsel installed a new operating system Counsel in error did not import the due date of June 22, 2011 to file the Social Security Verification Page. 5. Counsel has completed the Social Security Verification Page with debtor's redacted social security number to maintain her privacy (See Exhibit 1).

6.

If this Honorable Court would reinstate this case Counsel will file a non-redacted Social Security Verification Page within 24 hours of receiving notice from this Court.

7.

Counsel contends that by reinstating this petition no party will be prejudiced or harmed.

WHEREFORE, the Debtor requests that the foregoing Motion to Reinstate be granted.

By:/sl Jonathan Hoover


Jonathan Hoover, Esq. Attorney For Debtor 218 East Lexington Street, Suite 501 Baltimore, Maryland 21202 Telephone: 410-625-8301 jhoover@lawhoover.com

CERTIFICATE OF SERVICE I HEREBY CERTIFY that, on this 25th day of June 2011, after reviewing the Court's ECF Records, all parties required to be served with a copy of the foregoing paper should receive a copy electronically from the Court, except for the following person(s) to whom a copy is being mailed first class, postage prepaid to:

Monique Oliver, 1933 Brooks Drive Apt 202, Capital Heights, Maryland 20743.

Isl Jonathan Hoover


Jonathan Hoover

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