UNITED STATES BANKRUPTCY COURT 

EASTERN DISTRICT OF VIRGINIA 

Richmond Division 

In re: Vorcinthia Pope ) 

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 Case No. 15-33785-KRH 

 Debtor. Chapter 13 

 

Address 

Vorcinthia Pope 

5800 Thorndale Ln, Appt 1 

Richmond, VA 23234 

 

Last four digits of SSN or ITIN: 5919 

NOTICE OF OBJECTION TO PROOF OF CLAIM 

Richard J. Oulton, Esq. has filed papers with this court Objecting to a Proof of Claim. 

Your rights may be affected. You should read these papers carefully, and discuss 

them with your attorney in this Bankruptcy Case, if you have one. (If you do not have an 

attorney, you may wish to consult one.) 

If you do not want the court to grant the relief sought in the motion, or if you want the 

court to consider your views on the motion, then on or before 30 DAYS FROM TODAY, you or 

your attorney must: 

File with the court and mail a copy to the Debtors’ counsel, at the addresses shown below, 

a written request for a hearing. If you mail your request for hearing to the court for filing, you 

must mail it early enough so the court will receive it on or before the date stated above. 

Clerk of the Court 

U.S. Bankruptcy Court 

701 E. Broad St., Suite 4000 

Richmond, VA 23219 

Richard J. Oulton, Esq. 

America Law Group, Inc. 

8501 Mayland Dr. Suite 106 

Henrico, VA 23294 

You must also attend a hearing to be scheduled at a later date. 

If you or your attorney do not take these steps, the court may decide that you do not oppose 

the relief sought in the motion, and may enter an order granting that relief. 

Date: March 29, 2016 /s/ Richard J. Oulton, Esq. 

Richard J. Oulton, Esq.

America Law Group, Inc. 

8501 Mayland Dr. Suite 106 

Henrico, VA 23294 

Case 15-33785-KRH Doc 25 Filed 03/29/16 Entered 03/29/16 09:38:38 Desc Main

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Counsel for Debtor in Bankruptcy

CERTIFICATE OF SERVICE

See certification in Application Attached hereto 

UNITED STATES BANKRUPTCY COURT 

EASTERN DISTRICT OF VIRGINIA 

Richmond Division 

In re: Vorcinthia Pope ) 

) 

) 

) 

) 

) 

) 

) 

) 

 Case No. 15-33785-KRH 

 Debtor. Chapter 13 

 

Address 

Vorcinthia Pope 

5800 Thorndale Ln, Appt 1 

Richmond, VA 23234 

 

Last four digits of SSN or ITIN: 5919 

OBJECTION TO PROOF OF CLAIM 

COMES NOW, America Law Group, Inc., counsel for Debtor(s), and pursuant to FRBP 3001, 

and 11 USC 502, and objects to the proof of claim of 11, and says as follows: 

1. The claim is filed by Community Home Financial Services, Inc. . 

2. Upon information and belief of the Debtors, this claim is for a residence that was 

foreclosed pre-petition. The creditor is NOT entitled to be treated as a secured 

creditor, but any deficiency may be treated as an unsecured debt. In order for the 

creditor to be entitled to a deficiency, it must comply with state law. 11 USC 502. 

a. The subject property was foreclosed in 2009, and not later than 2010 was 

titled in the name of the foreclosure buyer. 

b. Pursuant to 11 USC 502(b)(1), the claim should be allowed as an 

UNSECURED claim because there is no collateral that is subject to 

repossession or foreclosure.. 

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3. This claim that was filed by Community Home Financial Services, Inc should be 

disallowed. 

WHEREFORE, debtor(s) respectfully requests that your Honorable Court disallow 

Claim #11, filed by Community Home Financial Services, Inc. in the amount of $8,883.71, be 

disallowed and order such other and further relief as is just and proper. 

/s/ Richard J. Oulton, Esq. 

Richard J Oulton, Esq. VSB# 

America Law Group, Inc. 

8501 Mayland Dr. Suite 106 

Henrico, VA 23294 

Tel: 804.308.0051 Fax: 804.308.0053 

jkrumbein@krumbeinlaw.com 

CERTIFICATE OF SERVICE 

I certify that I have this 29 March 2016, transmitted a true copy of the foregoing 

application electronically through the court’s CM/ECF system to the Chapter 13 Trustee and US 

Trustee, and by regular mail to the to the Debtor and 

Community Home Financial Services, Inc 

c/o C. Ellis Brazeal, III 

1819 5th Ave N. Suite 1100 

Birmingham, AL 35203 

Clearspring Loan Services 

c/o Payment Processing 

18451 North Tollway Suite 100 

Dallas, TX 75287 

/s/ Richard J. Oulton, Esq. 

Counsel for the Debtor(s) in Bankruptcy 

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