UNITED STATES BANKRUPTCY COURT 

FOR THE 

EASTERN DISTRICT OF VIRGINIA 

Alexandria Division

In the Matter of: 

DENNIS WAYNE MORGAN

AND

LISA DAWN MORGAN

Debtors 

Chapter 13 

Case No. 15-13395-BFK 

OBJECTION TO CLAIM 

NOTICE OF OBJECTION TO CLAIM

AND 

NOTICE OF SCHEDULED HEARING ON THIS OBJECTION

To: 

U.S. Bank Trust National Association, as 

Trustee of the SCIS Series III Trust 

BSI Financial Services 

1425 Greenway Drive, Ste. 400 

Irving, TX 75038 

Incorp Services, Inc. 

Registered Agent for 

BSI Financial Services 

7288 Hanover Green Dr. 

Mechanicsville, VA 23111 

Andrew Cecere, Chairman/Pres./CEO 

U.S. Bank Trust National Association 

300 East Delaware Ave., 8th Floor 

Wilmington, DE 19809 

Office of the Secretary 

of the Commonwealth 

1111 East Broad Street, 4th Floor 

Richmond, VA 23219 

Dennis Wayne Morgan 

Lisa Dawn Morgan 

12849 Elk Run Road 

Midland, VA 22728 

John C. Morgan, Jr., Esquire 

Attorney for Debtor 

New Day Legal, PLLC 

98 Alexandria Pike, Ste. 10 

Warrenton, VA 20186 

You have filed a claim in the amount of $413,450.68 (arrearage of $38,014.15) 

with a Court claim number of 7 in this Chapter 13 case. 

Thomas P. Gorman, Chapter 13 Trustee, has filed this objection to your filed claim 

and asks that the remaining balance be disallowed the Plan confirmed in this case on 

February 6, 2019 provides for the property to be surrendered, relief from the 

automatic stay has been granted by an Order entered August 31, 2018 and no 

claim for the unsecured or deficiency balance has been filed. 

Case 15-13395-BFK Doc 72 Filed 06/05/19 Entered 06/05/19 10:54:49 Desc Main

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Objection to Claim, page 2 

15-13395-BFK, Dennis Wayne and Lisa Dawn Morgan 

Your claim may be reduced, modified or eliminated. You should read these 

papers carefully and discuss them with your attorney, if you have one. (If you do not 

have an attorney, you may wish to consult one.)

If you do not wish 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 five business days prior 

to the hearing date, you or your attorney must: 

File with the court a written response with supporting memorandum as required by 

Local Bankruptcy Rule 9013-1(H). Unless a written response and supporting 

memorandum are filed and served by the date specified, the Court may deem any 

opposition waived, treat the motion as conceded, and issue an order granting the 

requested relief without further notice or hearing. If you mail your response to the 

court for filing, you must mail it early enough so the court will receive it on or before 

five business days prior to the scheduled hearing. You must mail a copy to the 

persons listed below. 

Attend the hearing to be held on July 25, 2019 at 1:30 p.m. in Courtroom #1 on the 

2nd floor, United States Bankruptcy Court, 200 South Washington Street, 

Alexandria, Virginia 22314. If no timely response has been filed opposing the relief 

requested, the court may grant the relief without holding a hearing. 

A copy of any written response must be mailed to the following persons: 

Thomas P. Gorman 

300 North Washington Street, Ste. 400 

Alexandria, VA 22314 

Clerk of the Court 

United States Bankruptcy Court 

 200 South Washington Street 

Alexandria, VA 22314 

Case 15-13395-BFK Doc 72 Filed 06/05/19 Entered 06/05/19 10:54:49 Desc Main

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Objection to Claim, page 2 

15-13395-BFK, Dennis Wayne and Lisa Dawn Morgan 

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

oppose objection to your claim. 

Date: June 5, 2019 ___/s/ Thomas P. Gorman _____ 

Thomas P. Gorman 

Chapter 13 Trustee 

300 N. Washington St.; Ste. 400 

Alexandria, VA 22314 

(703) 836-2226 

VSB 26421 

CERTIFICATE OF SERVICE 

I hereby certify that I have this 5th day of June, 2019, served via ECF to authorized 

users or mailed a true copy of the foregoing Objection to Claim, Notice of Objection, and 

Notice of Hearing to the parties listed in the heading hereof. 

/s/ Thomas P. Gorman ________ 

Thomas P. Gorman 

Case 15-13395-BFK Doc 72 Filed 06/05/19 Entered 06/05/19 10:54:49 Desc Main

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