Elizabeth C. Brogan

Counsel for Suzanne E. Wade, Chapter 13 Trustee

Virginia State Bar Number 76539

1313 East Main Street, Suite A

Post Office Box 1780

Richmond, Virginia 23218-1780

(804) 775-0979

UNITED STATES BANKRUPTCY COURT

EASTERN DISTRICT OF VIRGINIA

RICHMOND DIVISION

 In re: Lawson E. Wilson, ) Case No. 15-35751-KLP

 Artie Irene Wilson, Debtors ) Chapter 13

OBJECTION TO CONFIRMATION

COMES NOW Elizabeth C. Brogan, Counsel for Suzanne E. Wade, Chapter 13 Trustee, and 

moves this Court to deny confirmation of the Chapter 13 Plan (the “Plan”) dated November 6, 2015, for 

the cause as follows:

1. The Debtors filed this Chapter 13 Petition, now pending in the United States Bankruptcy 

Court, Eastern District of Virginia, Richmond Division, on November 6, 2015 under 11 

U.S.C. Chapter 13.

2. This Objection is filed pursuant to 11 U.S.C. § 1325(a)(4).

3. The above-filed Chapter 13 case is not eligible for confirmation due to the Plan’s failure to 

propose payment to unsecured creditors in an amount equivalent to that they would receive 

through a Chapter 7 liquidation. Specifically, paragraph 4A of the Debtors’ Plan states the 

estimated distribution to unsecured claims is approximately 5%, but that the same creditors 

would receive a dividend of approximately 27.85% if the case was liquidated under Chapter 

7. The Trustee requests the Debtors file an amended Plan increasing the dividend paid to 

unsecured creditors.

WHEREFORE, for the reasons stated herein, the Chapter 13 Trustee, by Counsel, respectfully moves 

the Court to deny confirmation of the Debtors’ proposed Chapter 13 Plan, and for such further and other 

relief as the Court deems necessary.

 Date: January 11, 2016 /s/ Elizabeth C. Brogan______________ 

 Elizabeth C. Brogan, Counsel for

 Suzanne E. Wade, Chapter 13 Trustee 

Case 15-35751-KLP Doc 14 Filed 01/11/16 Entered 01/11/16 14:47:31 Desc Main

 Document Page 1 of 4
Elizabeth C. Brogan

Counsel for Suzanne E. Wade, Chapter 13 Trustee

Virginia State Bar Number 76539

1313 East Main Street, Suite A

Post Office Box 1780

Richmond, Virginia 23218-1780

(804) 775-0979

CERTIFICATE OF SERVICE

I hereby certify a true copy of the foregoing OBJECTION TO CONFIRMATION was served 

electronically or by first-class mail, postage prepaid, this 11th day of January, 2016, upon the following 

parties:

Lawson E. & Artie Irene Wilson

157 Falkland Road 

Meherrin, VA 23954

Brian K. Stevens, Counsel for Debtor

America Law Group 

2312 Boulevard 

Colonial Heights, VA 23834 

bkstevens1534@gmail.com

 /s/ Elizabeth C. Brogan______________ 

 Elizabeth C. Brogan, Counsel for

 Suzanne E. Wade, Chapter 13 Trustee 

Case 15-35751-KLP Doc 14 Filed 01/11/16 Entered 01/11/16 14:47:31 Desc Main

 Document Page 2 of 4
Elizabeth C. Brogan

Counsel for Suzanne E. Wade, Chapter 13 Trustee

Virginia State Bar Number 76539

1313 East Main Street, Suite A

Post Office Box 1780

Richmond, Virginia 23218-1780

(804) 775-0979

UNITED STATES BANKRUPTCY COURT

EASTERN DISTRICT OF VIRGINIA

RICHMOND DIVISION

 In re: Lawson E. Wilson, ) Case No. 15-35751-KLP

 Artie Irene Wilson, Debtors ) Chapter 13

)

 157 Falkland Road )

 Meherrin, VA 23954 )

)

 XXX-XX-4033 )

 XXX-XX-8182 )

NOTICE OF OBJECTION TO CONFIRMATION

Elizabeth C. Brogan, Counsel for Suzanne E. Wade, Chapter 13 Trustee, has filed papers with 

the Court objecting to the confirmation of your Chapter 13 Plan dated November 6, 2015.

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

your attorney, if you have one in this bankruptcy case. 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 Objection, or if you want the Court 

to consider your views on the Objection, then on or before three (3) days before the date of the hearing, 

you or your attorney must:

_X_ File with the Court, at the address shown below, a written response pursuant to Local 

Bankruptcy Rule 9013-1(H). If you mail your response to the Court for filing, you must 

mail it early enough that the Court will receive it on or before the date stated above.

Clerk of Court

United States Bankruptcy Court

701 East Broad Street, Suite 4000

Richmond, Virginia 23219

You must also mail a copy to:

Elizabeth C. Brogan

Counsel for Suzanne E. Wade, Chapter 13 Trustee

Post Office Box 1780

Richmond, Virginia 23218-1780

Case 15-35751-KLP Doc 14 Filed 01/11/16 Entered 01/11/16 14:47:31 Desc Main

 Document Page 3 of 4
Elizabeth C. Brogan

Counsel for Suzanne E. Wade, Chapter 13 Trustee

Virginia State Bar Number 76539

1313 East Main Street, Suite A

Post Office Box 1780

Richmond, Virginia 23218-1780

(804) 775-0979

_X_ Attend the hearing on the Objection, scheduled to be held on January 20, 2016 at 

9:10 a.m. at United States Bankruptcy Court, 701 East Broad Street, Room 5100, 

Richmond, VA 23219.

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

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

Date: January 11, 2016 /s/ Elizabeth C. Brogan______________ 

 Elizabeth C. Brogan, Counsel for

 Suzanne E. Wade, Chapter 13 Trustee

CERTIFICATE OF SERVICE

I hereby certify a true copy of the foregoing NOTICE OF OBJECTION TO CONFIRMATION

was served electronically or by first-class mail, postage prepaid, this 11th day of January, 2016, upon 

the following parties:

Lawson E. & Artie Irene Wilson

157 Falkland Road 

Meherrin, VA 23954

Brian K. Stevens, Counsel for Debtor

America Law Group 

2312 Boulevard 

Colonial Heights, VA 23834 

bkstevens1534@gmail.com

 /s/ Elizabeth C. Brogan______________ 

 Elizabeth C. Brogan, Counsel for

 Suzanne E. Wade, Chapter 13 Trustee 

Case 15-35751-KLP Doc 14 Filed 01/11/16 Entered 01/11/16 14:47:31 Desc Main

 Document Page 4 of 4