___________________________________ 

Janet M. Meiburger, VA Bar No. 31842 

The Meiburger Law Firm, P.C. 

1493 Chain Bridge Road, Suite 201 

McLean, VA 22101 

(703) 556-7871 

Proposed Counsel to Chapter 7 Trustee 

IN THE UNITED STATES BANKRUPTCY COURT 

FOR THE EASTERN DISTRICT OF VIRGINIA 

ALEXANDRIA DIVISION 

__________________________________________ 

 ) 

IN RE: ) 

 ) 

SUSAN JEANETTE PALMA ) Case No. 16-10471-BFK 

DONALD CRAIG PALMA ) Chapter 7 

 ) 

Debtors ) 

__________________________________________) 

 

TRUSTEE’S OBJECTION TO DEBTORS’ CLAIM OF EXEMPTIONS 

 Pursuant to Federal Rule of Bankruptcy Procedure 4003, Janet M. Meiburger, the Trustee 

for the bankruptcy estate in the above-named case, hereby objects to the Debtors’ claim of 

exemptions pursuant to Va. Code Ann. § 34-4, and in support of this objection states as follows: 

1. On February 11, 2016 (the “Petition Date”), the Debtors filed their voluntary 

petition for relief under Chapter 7 of the Bankruptcy Code. The Trustee was appointed on 

February 12, 2016 (Docket No. 3). 

2. The Trustee believes that there is equity in the property located at 302 Ingelwood 

Drive, Rochester, New York 14619 (the “Property”). The Property is owned by Mr. Palma and 

his ex-wife Lucy K. Palma. 

3. The Debtors’ Schedule C claims exemptions in certain of the Debtors’ assets 

pursuant to VA. CODE ANN. § 34-4, including the Debtors’ bank accounts, the Property, and the 

Debtors’ possible 2015 tax refunds. 

4. The Trustee searched the land records in Loudoun County and could not find a 

recorded Homestead Deed for the Debtors. In addition, the Trustee requested a copy of any 

Case 16-10471-BFK Doc 22 Filed 04/25/16 Entered 04/25/16 15:20:34 Desc Main

 Document Page 1 of 3
2 

homestead deed from the Debtors’ attorney; however, the Debtors’ attorney did not respond. 

Therefore, the Trustee believes that no Homestead Deed has been filed. Accordingly, the 

Trustee objects to the Debtors’ claim of assets as exempt under VA. CODE ANN. § 34-4. 

WHEREFORE, Janet M. Meiburger, the Chapter 7 Trustee, respectfully requests that the 

Court enter an Order denying the Debtors’ claim of exemptions on Schedule C pursuant to VA.

CODE ANN. § 34-4, and granting such further relief as the Court deems appropriate under the 

circumstances. 

 Respectfully submitted, 

 THE MEIBURGER LAW FIRM, P.C. 

Dated: April 25, 2016 By: /s/ Janet M. Meiburger 

 Janet M. Meiburger, VSB No. 31842 

 The Meiburger Law Firm, P.C. 

 1493 Chain Bridge Road, Suite 201 

 McLean, VA 22101 

 (703) 556-7871 

 Proposed Counsel to Chapter 7 Trustee 

Case 16-10471-BFK Doc 22 Filed 04/25/16 Entered 04/25/16 15:20:34 Desc Main

 Document Page 2 of 3
3 

CERTIFICATE OF SERVICE

 I HEREBY certify that on this 25th day of April, 2016, a true and correct copy of the 

foregoing Trustee’s Objection to Debtors Claim of Exemptions will be served by ECF e-mail 

pursuant to the applicable Standing Order of the Court, and by first class mail, postage prepaid 

on the following: 

Donald & Susan Palma 

17626 Duke Street 

Dumfries, VA 22026 

 /s/ Janet M. Meiburger 

 Janet M. Meiburger 

 

J:\Trustee\Palma, Susan & Donald (16-10471)\Pleadings\Exemption Objection.1.doc 

Case 16-10471-BFK Doc 22 Filed 04/25/16 Entered 04/25/16 15:20:34 Desc Main

 Document Page 3 of 3