James E. Kane (VSB #30081) 

KANE & PAPA, P.C. 

1313 East Cary Street 

Richmond, VA 23219 

Telephone: (804) 225-9500 

Facsimile: (804) 225-9598 

Email: jkane@kaneandpapa.com 

Counsel for Debtors 

IN THE UNITED STATES BANKRUPTCY COURT 

FOR THE EASTERN DISTRICT OF VIRGINIA 

Richmond Division 

 

IN RE: ) 

 ) 

ALONZO LEE BONNER, SR. ) 

SHIRLEY HARRIS BONNER ) Case No. 16-35775-KLP 

 ) Chapter 13 

 Debtors ) 

 ) 

WILMINGTON SAVINGS FUND ) 

SOCIETY, FSB, ET SEQ. ) 

 ) 

 Movant ) 

 ) 

v. ) 

 ) 

ALONZO LEE BONNER, SR., ET AL. ) 

 ) 

 Respondents ) 

DEBTORS’ RESPONSE TO MOTION FOR RELIEF FROM AUTOMATIC STAY 

COMES NOW the Debtors, by counsel, and as and for Debtors’ Response to Wilmington 

Savings Fund Society, FSB, d/b/a Christiana Trust, not individually but as Trustee for Pretium 

Mortgage Acquisition Trust’s (“Movant”) Motion for Relief From the Automatic Stay 

(“Motion”), states as follows: 

 1. The allegations contained in paragraphs 1, 2, 3, 4, 5, 6, 7 and 11 of the Motion are 

admitted. 

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 2. The allegations contained in paragraphs 8, 9, 10, and 12 of the Motion are denied 

and the Debtors demand strict proof thereof. 

3. In support of their denial of the allegations contained in the Motion, the Debtors 

affirmatively state: 

 a. At the time of Movant’s filing of the Motion, the Debtors were current 

with their post-petition payments to Movant. 

 b. The Movant’s Motion alleges that the Debtors were post-petition 

delinquent for periods wherein the Debtors have proof of payment which were provided to the 

Movant. The Movant has admitted to receiving all of the payments except for one (1) payment 

which was believed to have been lost in the mail. 

 c. The Debtors are not liable for this payment nor are they liable for the legal 

fees as their post-petition payments to the Movant were current at the time of the filing of the 

Motion. 

 d. Debtors’ counsel made an additional attempt to resolve the matter with 

Movant and Movant failed and refused to discuss a resolution. 

 WHEREFORE, the Debtors respectfully request that Movant’s Motion for Relief From 

the Automatic Stay be denied, and for such other relief as the Court deems appropriate. 

 ALONZO LEE BONNER, SR. 

SHIRLEY HARRIS BONNER 

 

 By: /s/ James E. Kane 

 Counsel 

Case 16-35775-KLP Doc 50 Filed 01/21/20 Entered 01/21/20 12:41:07 Desc Main

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James E. Kane (VSB #30081) 

KANE & PAPA, P.C. 

1313 East Cary Street 

Richmond, VA 23219 

Telephone: (804) 225-9500 

Facsimile: (804) 225-9598 

Email: jkane@kaneandpapa.com 

Counsel for Debtors 

CERTIFICATE OF SERVICE 

I hereby certify that on January 21, 2020, I will electronically file the foregoing with the 

Clerk of Court using the CM/ECF system, which will then send a notification of such filing 

(NEF) to all parties registered to receive notice thereof. 

 /s/ James E. Kane 

James E. Kane (VSB #30081) 

KANE & PAPA, P.C. 

1313 East Cary Street 

Richmond, Virginia 23219 

Telephone: (804) 225-9500 

Facsimile: (804) 225-9598 

Email: jkane@kaneandpapa.com 

Case 16-35775-KLP Doc 50 Filed 01/21/20 Entered 01/21/20 12:41:07 Desc Main

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