IN THE UNITED STATES BANKRUPTCY COURT FOR
THE ___________________________________DISTRICT OF
__________________________________________________ (Name of State)
IN RE: _______________________________________ CASE NO._____________
(DEBTOR)
___________________________________ CREDITOR PLAINTIFF
V. ADV. PROC. NO.________
_____________________________________ DEBTOR DEFENDANT
COMPLAINT
1. Plaintiff, _______________________________________________ (Creditor), of
________________________________________________________________________
________________________________________________________________________
_______________________________ (street address, city, county, state, zip code), is a
creditor of the above-named Debtor.
2. Defendant, ______________________________________________ (Debtor), of
________________________________________________________________________
________________________________________________________________________
___________________________________ (street address, city, county, state, zip code),
is the Debtor in the above-captioned proceedings.
3. This is an action under 11 U.S.C.A. § 727(c) objecting to the discharge of the
Defendant Debtor. The court has jurisdiction of this case pursuant to 28 U.S.C.A. § 1334.
4. Attorney for Plaintiff has investigated the actions of Debtor and being satisfied
that the proper grounds exist for denial of the discharge of the Debtor, objects to granting
of discharge of the Debtor. The grounds for such objection is set forth in the following
paragraphs.
5. On __________________________________ (date of transfer) , Debtor, for the
purpose of hindering, delaying, and defrauding Debtor's creditors, transferred to
____________________________________________________ ( name of transferee)
certain of Debtor's property as follows: ________________________________________
________________________________________________________________________
________________________________________________________________________
(describe transferred property) .
6. Debtor knowingly and fraudulently omitted the property from Debtor's Schedule
of assets filed in this proceeding, and failed to reveal to the trustee the existence of the
property or the facts as to its title, and fraudulently and knowingly concealed the property
as belonging to the Debtor's estate, from Debtor's trustee.
7. For the reasons shown above, Debtor should be denied discharge.
THEREFORE, Plaintiff prays that:
A. That Debtor be ordered to amend and supplement Debtor's Petition and
Schedules _______________________________________________________________
_________________________________________________ (specify schedule
numbers ) so as to show the names, addresses, and dates when the indebtedness was
incurred, and the amounts due all of Debtor's creditors and to show specifically the dates
when the indebtedness as to the creditors already listed were incurred;
B. If the supplemental and amended Petition be not received and filed in this
Honorable Court within the next __________ (number) days, then Plaintiff prays that no
discharge be granted to the Debtor;
C. Plaintiff further prays that Debtor be denied a discharge for
the several reasons alleged in the above and foregoing Complaint.
D. That this Honorable Court set the day and date for hearing on this
objection to discharge and further prays for all orders and decrees necessary in the
premises.
Respectfully Submitted,
____________________________________
CREDITOR
By_________________________________
(Name of Attorney)
Plaintiff’s Attorney
Certificate of Service
This is to certify that I, ___________________________________________
(Name of Attorney), attorney for _____________________________________________
(Creditor), Plaintiff in the above-styled and numbered adversary proceeding, have this
date served a true and correct copy of the above and foregoing Complaint by U.S. Mail,
postage fully prepaid, to the following counsel of record for Defendant:
_____________________________________________________ (Name of Attorney)
Post Office Box ________-____________
City, State, Zip Code _____________________________________________________
____________________________
This the _____ day of ______________________________________, 20____.
Respectfully Submitted,
____________________________________
(Name of Attorney)
State Bar No. _______
Attorney for Plaintiff
OF COUNSEL:
___________________________________________ (Name of Attorney)
Post Office Box ________-______________
City, State, Zip Code ______________________________________________________
____________________________
Telephone: _______-_______-____________
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FAQs
Here is a list of the most common customer questions. If you can’t find an answer to your question, please don’t hesitate to reach out to us.
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