Section 11.28 MOW 4004-4.2 Form, Debtor’s Motion for Entry of Chapter 13 Discharge Due to Hardship and Notice of Deadline and Opportunity to Object

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UNITED STATES BANKRUPTCY COURT WESTERN DISTRICT OF MISSOURI

IN RE:

Debtor(s)

Case No.

DEBTOR’S MOTION FOR ENTRY OF CHAPTER 13 DISCHARGE DUE TO HARDSHIP AND NOTICE OF DEADLINE AND OPPORTUNITY TO OBJECT

Comes now the debtor and moves for the entry of an Order of Discharge pursuant to 11 U.S.C. §1328(b) despite the debtor’s failure to complete payments under the confirmed plan. In support thereof the debtor states:

1. “The debtor’s failure to complete such payments is due to circumstances for which the debtor should not justly be held accountable” in that . 11 U.S.C. §1328(b)(1).

2. “The value, as of the effective date of the plan, of property actually...