Rohit Kejriwal

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UNITED STATES BANKRUPTCY COURT
SOUTHERN DISTRICT OF OHIO
EASTERN DIVISION
In re: 	:
: 	Case No. 2:25-bk-54543
Rohit Kejriwal, 	: 	Chapter 7
: 	Judge Nami Khorrami
Debtor. 	:
:
ORDER DENYING MOTION TO EXTEND TIME TO OBJECT TO DISCHARGE OR
DISCHARGEABILITY FILED BY CREDITOR CHRISTINE ANTHONY (DOC. 20)
Before the Court is the Motion to Extend the “Time to File to Object to Discharge”
Deadline, (the “Motion”), Dkt. No. 201, which was filed on January 21, 2026, by pro se creditor
Christine Anthony (“Ms. Anthony”).2 	Rohit Kejriwal, the debtor in this case (“Mr. Kejriwal”),
1 The docket of this case shows the Motion as Doc. 20. Due to a technical issue, the Motion itself bears the numerical
stamp of Doc. 20-2. The Motion will be referred to herein as Doc. 20.
2 Although the Motion states that it seeks to extend the time to object to the discharge from January 20, 2026, to March
15, 2026, the Court construes it as requesting an extension of the deadlines both for an objection to discharge under
11 U.S.C. § 727 and to the dischargeability of the debt owed to Ms. Anthony under 11 U.S.C. § 523(a)(2), (4), or (6).
________________________________________________________________
This document has been electronically entered in the records of the United
States Bankruptcy Court for the Southern District of Ohio.
IT IS SO ORDERED.
Dated: March 27, 2026
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filed an objection to the Motion. 	Obj., Dkt. No. 30. A pretrial conference (the “Hearing”) was
held telephonically on March 24, 2026. 	Kenneth Richards appeared for Mr. Kejriwal, and Ms.
Anthony appeared pro se. For the following reasons, the Court denies the Motion.
This Court has jurisdiction over this matter pursuant to 28 U.S.C. § 1334 and the Amended
General Order 05-02 entered by the United States District Court for the Southern District of Ohio,
referring all bankruptcy matters to this Court. This matter is a core proceeding pursuant to 28
U.S.C. § 157(b)(2)(A), (I), (J), and (O). In re Vinson, 509 B.R. 128, 130 (Bankr. S.D. Ohio 2013).
Venue properly lies in this Court pursuant to 28 U.S.C. §§ 1408 and 1409.
The time to object to discharge under 11 U.S.C. § 727(a) or to object to the dischargeability
of a particular debt under 11 U.S.C. § 523(a)(2), (4), or (6) is governed by Rules 4004(a)(1) and
4007(c) of the Federal Rules of Bankruptcy Procedure (“Bankruptcy Rules”). In each case, the
deadline is sixty days after the first date set for the meeting of creditors under 11 U.S.C. § 341.
Fed. R. Bankr. P. 4004(a)(1), 4007(c). Bankruptcy Rules 4004(b)(1) and 4007(c) provide that the
time to object to discharge and/or dischargeability may be extended upon motion to the Court, but
only if the motion is filed before the deadline has expired. Fed. R. Bankr. P. 4004(b)(1), 4007(c).3
Further, Bankruptcy Rule 9006(b)(3) states that the Court can extend the deadlines set in
Bankruptcy Rules 4004(a) and 4007(c) “only as permitted by those rules.”
In this case, on October 17, 2025, the Clerk’s Office issued a notice (as required by
Bankruptcy Rules 2002(a), 4004(a)(4), and 4007(c)) giving all parties in interest notice that the
meeting of creditors was set for November 20, 2025, and that the deadline to object to discharge
3 Bankruptcy Rule 4004(b)(2) permits a motion to extend the time to file an objection to discharge that is filed after
the deadline, but only where “(A) the objection is based on facts that, if learned after the discharge is granted, would
provide a basis for revocation under §727(d); (B) the movant did not know those facts in time to object; and (C) the
movant files the motion promptly after learning about them.” Fed. R. Bankr. P. 4004(b)(2). The Motion does not
allege any facts that would implicate Bankruptcy Rule 4004(b)(2).
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and/or the dischargeability of a particular debt was January 20, 2026. 	Notice of Chapter 7
Bankruptcy Case 2, Dkt. No. 7. A notice of these deadlines was sent to Ms. Anthony by regular
U.S. Mail on October 19, 2025. Certificate of Notice 3, Dkt. No. 8.
Ms. Anthony filed the Motion on January 21, 2026, one day after the January 20, 2026,
deadline. 	Mot., Dkt. No. 20. 	Ms. Anthony stated that she mailed the Motion to the Court on
January 17, 2026, via United States Postal Service Priority Mail Express, but it arrived a day later
than she anticipated. Mot. 4, Dkt. No. 20. Ms. Anthony intended for the Motion to be received
by the Court no later than January 20, 2026, and represented to the Court that the Postal Service
had given her a partial refund due to the late delivery.
Cases interpreting Bankruptcy Rules 4004(b), 4007(c) and 9006(b)(3) hold that courts
cannot extend the deadline after it has expired except in the unusual case in which the court itself
misled a party about the deadline. “Absent an error by the Court resulting in a creditor missing
the deadline, a bankruptcy court can extend the deadline only on motion filed before the deadline
expires.” Mittman v. Casey (In re Casey), 329 B.R. 43, 46 (Bankr. S.D. Ohio 2005) (citing Ohio
Farmers Ins. Co. v. Leet (In re Leet), 274 B.R. 695, 697-98, 700-701 (B.A.P. 6th Cir. 2002)). The
courts reason that, taken together, the rules reflect an intent that the deadlines must be enforced as
written and not subject to equitable tolling. Leet, 274 B.R. at 700-701.
These cases reflect the Supreme Court’s approach to timelines set by all the federal
procedural rules. “Where the pertinent rule or rules invoked show a clear intent to preclude tolling,
courts are without authority to make exceptions merely because a litigant appears to have been
diligent, reasonably mistaken, or otherwise deserving.” Nutraceutical Corp. v. Lambert, 586 U.S.
188, 192-93, 139 S. Ct. 710, 203 L. Ed. 2d 43 (2019). If those time limits are properly invoked by
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the opposing party, courts must enforce them.4 Nutraceutical, 586 U.S. at 193 (“Appellate Rule
26(b) says that the deadline for the precise type of filing at issue here may not be extended. The
Rules thus express a clear intent to compel rigorous enforcement of Rule 23(f)’s deadline, even
where good cause for equitable tolling might otherwise exist.”).5 Even though Ms. Anthony might
deserve an extension, the Court has no authority to grant it.
Because the Court simply has no authority to depart from the clear provisions of
Bankruptcy Rules 4004(a), 4007(c), and 9006(b)(3), the Motion is denied.
IT IS SO ORDERED.
Copies to: Default List
4 Mr. Kejriwal properly asserted the time limit. Obj. 1-2, Dkt. No. 30.
5 The Third Circuit recently applied Nutraceutical to Bankruptcy Rules 4007(c) and 9006(b)(3). In re Delloso, 72
F.4th 532, 540-41 (3rd Cir. 2023) (“Much like how the Supreme Court in Nutraceutical concluded that by singling
out Rule 23(f) for inflexible treatment the Federal Rules of Appellate Procedure showed an intent to make tolling
unavailable, we view Rule 9006(b)'s singling out of Rule 4007(c) as evidencing an intent to preclude equitable
tolling.”).
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