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Bruce A Thomason SBN 140596

Thomason Law Center
6520 Eastern Ave
Ste 206
Bell Gardens, CA 90201
Tel (323) 319-5435
Fax (323) 837-4766
Email: brucethomason@hotmail.com

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Attorneys for Micailina Ramirez

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UNITED STATES BANKRUPTCY COURT

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CENTRAL DISTRICT OF CALIFORNIA SAN FERNANDO DIVISION

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In re:

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MICAILINA RAMIREZ,
Debtor(s).

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Case No.: 1-14-bk-14572 MT

Chapter 13
NOTICE OF MOTION AND MOTION FOR
VACATE DISMISSAL AND REINSTATE
THE CHAPTER 13 PURSUANT 5010.1;
DECLARATION OF JOSE COVARRUBIAS;
DECLARATION OF BRUCE A.
THOMASON IN SUPPORT THEREOF.
Hearing Date:
Time:
Crtrm:
Floor:

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TO THE HONORABLE _MAUREEN A. TIGHE_; _ELIZABET ROJAS_ CHAPTER 13

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TRUSTEE; AND ALL OTHER INTERESTED PARTIES: Debtor Micailina Ramirez through her

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Attorney, Bruce A. Thomason, hereby give notice of Hearing re: Motion For Vacate Dismissal and

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Reinstate the Chapter 13 Pursuant 5010.1 would be heard on short notice at the

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- 1 MOTION TO VACATE THE DISMISSAL AND REINSTATE THE CHAPTER 13

U.S. Bankruptcy Court Central District of California located at 255 East Temple Street Los Angeles

Courtroom 1545, 15th Floor.

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I declare under the penalty of perjury under the laws of the State of California and United
States that the foregoing is true and correct.
Date: 05/01/2014

/s/ Bruce A. Thomason

Bruce A. Thomason, Esq.

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- 2 MOTION TO VACATE THE DISMISSAL AND REINSTATE THE CHAPTER 13

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1. Debtor through her attorney filed an emergency case under the U.S. Bankruptcy Code
Chapter 13 on April 03, 2014, electronically.
2. Debtor through his attorney filed a Statement of Social Security form electronically, on
April 09, 2014.
3. Debtor through his attorney filed a Declaration of Electronic Filing on April 09, 2014
4. Court clerk set the Meeting of Creditor 341(a) to be held on May 12, 2014 at 9:00 am,
Confirmation Hearing Schedule to be heard on May 12, 2014 at 9:00 a.m..
4. Debtor has enough income to submit a feasible chapter 13 plan.
5. The Court Clerk entered an Order and Notice of Dismissal for failure to file Schedules,
Statement and/or plan on April 25, 2014.
6. Debtor mistakenly believed he had filed the Credit Counseling and all required documents
to complete the filing of the petition.
7. Automatic Stay would not be affected by Debtor's reopening case.
8. Debtor prior dismissal occurred more than 12 months from the filing of this case.

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9. Debtor does not want to keep filing any more case to fear been consider as abusive.

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10. Debtor wishes to complete his chapter 13 case.

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11. Debtor has comply with all required steps and/or responsibilities including but not limited

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filing, and/or providing documents for review to trustee Rod Daniels prior to the filing of this motion.
12. For the foregoing reason, the Debtor respectfully request the court to reinstate the petition.

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Dated: 05/01/2014
Respectfully submitted.

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Bruce A. Thomason

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- 3 MOTION TO VACATE THE DISMISSAL AND REINSTATE THE CHAPTER 13

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Bruce A Thomason SBN 140596

Thomason Law Center
6520 Eastern Ave
Ste 206
Bell Gardens, CA 90201
Tel (323) 319-5435
Fax (323) 837-4766
Email: brucethomason@hotmail.com

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Attorneys for Jose Covarrubias

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UNITED STATES BANKRUPTCY COURT

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CENTRAL DISTRICT OF CALIFORNIA LOS ANGELES DIVISION

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In re:

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JOSE COVARRUBIAS,
Debtor.

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Case No.: 6:14-bk-14334 MJ

Chapter 13
DECLARATION OF JOSE COVARRUBIAS
IN SUPPORT OF REINSTATEMENT OF
THE CHAPTER 13 CASE PURSUANT TO
LBR 5010.1
Hearing Date:
Time:
Crtrm:
Floor:

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I, Jose Covarrubias, do declare as follows:

1. That I have personal knowledge of the facts stated herein, if called to testify, I could and
would do so competently thereto.

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2. That I am the Debtor in the above referenced case.

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3. I filed a Bankruptcy in this case to reorganize my debts on April 03, 2014.

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- 4 MOTION TO VACATE THE DISMISSAL AND REINSTATE THE CHAPTER 13

4. My financial has changed and I now have enough income to afford my chapter 13 plan.

5. I do not wish to re file any more case with fear to be consider abusive.

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6. I understand that all documents has been mailed to trustee Rod Danielson for his review
prior to the hearing set for May 12, 2014.
7. For the foregoing reasons, I respectfully request to the Court to reinstate the Chapter 13

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petition as I can propose a confirmable plan. To restart a new Chapter 13 would be burdensome to

me.

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I declare under penalty of perjury, under the Laws of these United States of America and
California that the foregoing is true and correct. Executed this 01st day of May, 2014 in Los Angeles,
California.

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Dated: 05/01/2014

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___________________________
Jose Covarrubias, Debtor

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- 5 MOTION TO VACATE THE DISMISSAL AND REINSTATE THE CHAPTER 13

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Bruce A Thomason SBN 140596

Thomason Law Center
6520 Eastern Ave
Ste 206
Bell Gardens, CA 90201
Tel (323) 319-5435
Fax (323) 837-4766
Email: brucethomason@hotmail.com

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Attorneys for Odila Campos

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UNITED STATES BANKRUPTCY COURT

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CENTRAL DISTRICT OF CALIFORNIA LOS ANGELES DIVISION

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In re:

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JOSE COVARRUBIAS,
Debtor.

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Case No.:6:14-bk-14334 MJ
Chapter 13
DECLARATION OF BRUCE A.
THOMASON RE: MOTION TO VACATE
THE DISMISSAL AND REINSTATE THE
CHAPTER 13 PURSUANT TO LBR 5010.1
Hearing Date:
Time:
Crtrm:
Floor:

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I, Bruce A. Thomason, do declare as follows:

1. That I have personal knowledge of the facts stated herein, if called to testify, I could and

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would do so competently thereto.

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2. That I am the Attorney for the Debtor herein.

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3. I filed a bankruptcy case under the chapter 13 on or about April 03, 2013.
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4. I believed all the required documents were filed promptly via the ECF website, Later to
find out that the Credit Counseling was missing and therefore the case was dismissal.
5. Debtor's automatic stay would not be affected due if case is reopen.
6. No creditor would be affected and/or abuse for the reopening of the case.
7. Debtor prior dismissal was more than 12 months ago.
8. For the foregoing reasons, the Debtor through their attorney respectfully request the Court
to reinstate the Chapter 13 Petition.
I declare under penalty of perjury, under the Laws of these United States of America and
California that the foregoing is true and correct. Executed this 1st day of May, 2014 in Los Angeles,
California.

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_______________________________
Bruce A. Thomason,

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Attorney for Movant/Debtor

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- 7 MOTION TO VACATE THE DISMISSAL AND REINSTATE THE CHAPTER 13

NOTE: When using this form to indicate service of a proposed order, DO NOT list any person or entity in Category I.
Proposed orders do not generate an NEF because only orders that have been entered are placed on the CM/ECF docket.

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PROOF OF SERVICE OF DOCUMENT

I am over the age of 18 and not a party to this bankruptcy case or adversary proceeding. My business address is:
707 Wilshire Blvd Ste 5150
Los Angeles, CA 90017
A true and correct copy of the foregoing document described
NOTICE OF MOTION AND MOTION

VACATE DISMISSAL AND REINSTATE THE CHAPTER 13 PURSUANT 5010.1;

DECLARATION OF JOSE COVARRUBIAS; DECLARATION OF BRUCE A. THOMASON IN
SUPPORT THEREOF served or was served (a) on the judge in chambers in the form and manner required by LBR
5005-2(d); and (b) in the manner indicated below:
I. TO BE SERVED BY THE COURT VIA NOTICE OF ELECTRONIC FILING (NEF) Pursuant to controlling
General Order(s) and Local Bankruptcy Rule(s) (LBR), the foregoing document will be served by the court via NEF
and hyperlink to the document. On 05/01/2014 I checked the CM/ECF docket for this bankruptcy case or adversary
proceeding and determined that the following person(s) are on the Electronic Mail Notice List to receive NEF
transmission at the email address(es) indicated below:
Rod (MJ) Danielson (TR)
notice-efile@rodan13.com
Bruce A Thomason on behalf of Debtor Jose Covarrubias
brucethomason@hotmail.com, alexsandovalsvc@gmail.com
United States Trustee (RS)
ustpregion16.rs.ecf@usdoj.gov
Service information continued on attached page
II. SERVED BY U.S. MAIL OR OVERNIGHT MAIL(indicate method for each person or entity served):
On
05/01/2014
I served the following person(s) and/or entity(ies) at the last known
address(es) in this bankruptcy case or adversary proceeding by placing a true and correct copy thereof in a sealed
envelope in the United States Mail, first class, postage prepaid, and/or with an overnight mail service addressed as
follows. Listing the judge here constitutes a declaration that mailing to the judge will be completed no later than 24 hours
after the document is filed.
Chase Home Mortgage
PO BOX 3990
Melbourne, FL 32901
Service information continued on attached page
III. SERVED BY PERSONAL DELIVERY, FACSIMILE TRANSMISSION OR EMAIL (indicate method for each
person or entity served): Pursuant to F.R.Civ.P. 5 and/or controlling LBR, on
I served the following person(s)
and/or entity(ies) by personal delivery, or (for those who consented in writing to such service method), by facsimile
transmission and/or email as follows. Listing the judge here constitutes a declaration that personal delivery on the judge
will be completed no later than 24 hours after the document is filed.

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FOR

Service information continued on attached page

I declare under penalty of perjury under the laws of the United States of America that the foregoing is true and correct.
05/01/2014
Date

Alejandro B Sandoval
Type Name

/S/ Alejandro B Sandoval

Signature

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