Discharge Bankruptcy

Complaint Objecting to Discharge

IN THE UNITED STATES BANKRUPTCY COURT FOR

THE DISTRICT OF

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 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

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 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,

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,