Debtor’s Motion to Reopen Case
The Debtor, by counsel, requests that the above-captioned case be reopened pursuant to 11 U.S.C. § 350(b) in order to accord relief to the Debtor and in support thereof avers as follows:
1. The Debtor filed bankruptcy pursuant to chapter 7 of the Bankruptcy Code on May 1, 2005, and received a discharge pursuant to 11 U.S.C. § 727 on September 10, 2005.
2. Among the debts listed in the Debtor’s petition and discharged in this bankruptcy case was a debt in the amount of $550 to [hospital].
3. [Hospital] received notice of the discharge on or about September 10, 2005.
4. In January, 2006, the Debtor began receiving calls from [collection agency] which represented that it was collecting the [hospital] debt.
5. The Debtor informed [collection agency] of the discharge by telephone and by letter, but nevertheless continued to receive collection calls and letters.
6. The Debtor has prepared an action against [hospital] and [collection agency] for contempt for violation of the discharge injunction applicable to this case by virtue of 11 U.S.C. § 524(a). A copy of that action is attached hereto and labeled Exhibit A [omitted].
WHEREFORE, the Debtor requests that this case be reopened to allow the Debtor to file and prosecute an action against [hospital] and [collection agency] for violation of the discharge injunction.
Attorney for Debtor
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