IN THE UNITED STATES BANKRUPTCY COURT 

FOR THE EASTERN DISTRICT OF VIRGINIA 

RICHMOND DIVISION 

RACHEL RENA MADDUX, et al., 

Consolidated Contested Matters 

Case Nos. 15-33574, 15-33590, 

15-34358, 15-34453, 15-35437, 

15-36032 

v. 

Debtors, 

MIDLAND CREDIT MANAGEMENT, INC., 

as Agent for MIDLAND FUNDING, LLC, 

 Creditor. 

NOTICE OF MOTION AND NOTICE OF HEARING 

PLEASE TAKE NOTICE that on December 15, 2016, Midland Credit Management, 

Inc., as Agent for Midland Funding, LLC (“Midland”), by and through their undersigned 

counsel, filed the Motion of Midland Credit Management, Inc., as Agent for Midland Funding, 

LLC, to Amend, Clarify and/or Make Additional Findings Pursuant to Bankruptcy Rule 7052 

[ECF No. 140] (the “Motion”) with the United States Bankruptcy Court for the Eastern District 

of Virginia, Richmond Division (the “Court”): 

PLEASE TAKE FURTHER NOTICE that your rights may be affected. You 

should read the Motion carefully and discuss them with your attorney, if you have one. (If 

you do not have an attorney, you may wish to consult one). 

PLEASE TAKE FURTHER NOTICE if you do not want the Court to grant the relief 

requested in the Motion, or if you want the Court to consider your views on the Motion, then, 

by January 18, 2017 (the “Objection Deadline”), you or your attorney must: 

 File with the Court, either electronically or at the address shown below, a written 

response to the Motion pursuant to Rule 9013-1(H) of the Local Rules of the 

United States Bankruptcy Court for the Eastern District of Virginia. If you mail 

your written response to the Court for filing, you must mail it early enough so the 

Court will receive it on or before the Objection Deadline. 

If a response is not properly and timely filed and served, the Court may 

deem any opposition waived, treat the Motion as conceded and enter an 

appropriate order granting the requested relief without further notice or 

hearing. 

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Clerk of the Court 

United States Bankruptcy Court 

701 East Broad Street 

Suite 4000 

Richmond, VA 23219 

 Attend a hearing before the Honorable Kevin R. Huennekens, United States 

Bankruptcy Judge, at 2:00 p.m. (prevailing Eastern Time) on Wednesday, 

January 25, 2017, at the United States Bankruptcy Court for the Eastern District 

of Virginia, Richmond Division, 701 East Broad Street, Room 5000, Richmond, 

Virginia 23219. 

Dated: December 16, 2016 Respectfully submitted, 

 

 /s/ Tyler P. Brown 

Tyler P. Brown (VSB No. 28072) 

Justin F. Paget (VSB No. 77949) 

HUNTON & WILLIAMS LLP 

Riverfront Plaza, East Tower 

951 East Byrd Street 

Richmond, Virginia 23219 

Telephone: (804) 788-8200 

Facsimile: (804) 788-8218 

Counsel to Midland Credit Management, Inc., as 

Agent for Midland Funding, LLC 

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CERTIFICATE OF SERVICE 

I hereby certify that on December 16, 2016, a true and accurate copy of the foregoing was 

served via First Class U.S. Mail (postage prepaid), via e-mail or via the Electronic Case Filing 

(ECF) system, as appropriate and as indicated, on the following parties: 

Mark C. Leffler, Esq.* 

Emily Connor Fort, Esq.* 

Boleman Law Firm, P.C. 

2104 Laburnum Avenue, Suite 201 

Richmond, VA 23227 

Counsel for Debtor 

Thomas D. Domonoske, Esq.* 

Consumer Litigation Associates 

281 N. Mason Street, #811 

Harrisonburg, VA 22803 

Counsel for Debtor 

Dale W. Pittman, Esq.* 

The Law Office of Dale W. Pittman, P.C. 

The Eliza Spotswood House 

112-A West Tabb Street 

Petersburg, VA 23803 

Counsel for Debtor 

Suzanne E. Wade, Esq.* 

P.O. Box 1780 

Richmond, VA 23218 

Trustee 

Carl M. Bates, Esq.* 

P. O. Box 1819 

Richmond, VA 23218 

Trustee 

/s/ Tyler P. Brown 

Tyler P. Brown 

[*Indicates service by ECF or e-mail. All others served by First Class U.S. Mail, postage prepaid.]

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