IN THE UNITED STATES BANKRUPTCY COURT 

FOR THE EASTERN DISTRICT OF VIRGINIA 

Richmond Division 

 

IN RE: ) 

 ) 

ROSINA DENISE COOK ) Case No. 16-32472-KRH 

 ) Chapter 13 

 Debtor ) 

MOTION TO INCUR DEBT 

 COMES NOW, the Debtor, by counsel, and as and for her Motion to Incur Debt, states as 

follows: 

 1. The Debtor filed this case under Chapter 13 of the U.S. Bankruptcy Code on May 

16, 2016. 

2. The Debtor has applied for and Movement Mortgage, LLC has approved a loan to 

the Debtor in the amount of $378,826.00 plus interest at 3.625% per annum to be repaid with 

estimated equal monthly payments of approximately $2,296.00 for principal and interest for the 

purchase of a home located at 8902 Mansfield Woods Drive, Henrico, Virginia 23231. The loan 

term is thirty 300 months. A copy of the Closing Disclosure is attached hereto as Exhibit “A” 

and incorporated herein by this reference. The closing costs are to be paid by the Debtor. 

3. The purchase of the Property is in the best interest of the Debtor and will facilitate 

his ability to perform under his Chapter 13 Plan filed herein. 

 4. The Debtor’s Chapter 13 Plan has been confirmed. 

WHEREFORE, the Debtor requests that the Court enter an Order approving the aforesaid 

loan on the terms stated herein and for such other relief as the Court may deem appropriate. 

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 ROSINA DENISE COOK 

 By: /s/ James E. Kane 

 Counsel 

James E. Kane (VSB #30081) 

KANE & PAPA, P.C. 

1313 East Cary Street 

Richmond, VA 23219 

(804) 225-9500 (phone) 

(804) 225-9598 (fax) 

Counsel for Debtor 

CERTIFICATE OF SERVICE 

I hereby certify that on May 6, 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 counsel of record who have signed up to receive such notification and by first class 

mail to the parties on the attached list.

 /s/ James E. Kane 

 James E. Kane 

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IN THE UNITED STATES BANKRUPTCY COURT 

FOR THE EASTERN DISTRICT OF VIRGINIA 

Richmond Division 

 

IN RE: ) 

 ) 

ROSINA DENISE COOK ) Case No. 16-32472-KRH 

 ) Chapter 13 

 Debtor ) 

NOTICE OF MOTION AND HEARING 

 The above Debtor has filed Motion to Incur Debt in the above matter. 

 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 motion, or if you want the 

court to consider your views on the motion, then, within twenty-one (21) days from the date of 

this Notice you or your attorney must: 

 File with the court, at the address shown below, a written request for a hearing [or 

written response pursuant to Local Bankruptcy Rule 9013-1(H)]. If you mail your 

request for a hearing (or response) to the court for filing, you must mail it early 

enough so the court will receive it on or before the date stated above, to: 

Clerk of Court 

United States Bankruptcy Court 

701 East Broad Street 

Richmond, VA 23219 

You must also mail a copy to: 

James E. Kane, Esquire 

Kane & Papa, P.C. 

1313 East Cary Street 

Richmond, Virginia 23219 

 Attend a hearing scheduled for May 13, 2020 at 12:00 p.m. at U.S. Bankruptcy 

Court, 701 East Broad Street, Room 5000, Richmond, VA 23219. If no 

timely response has been filed opposing the relief requested, the court may grant 

the relief without holding a hearing. 

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 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 or objection and may enter an order granting that 

relief. 

Dated: May 6, 2020 ROSINA DENISE COOK 

 By: /s/ James E. Kane 

 Counsel 

James E. Kane (VSB #30081) 

KANE & PAPA, P.C. 

1313 East Cary Street 

Richmond, VA 23219 

(804) 225-9500 (phone) 

(804) 225-9598 (fax) 

Counsel for Debtor 

CERTIFICATE OF SERVICE 

I hereby certify that on May 6, 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 counsel of record who have signed up to receive such notification and by first class 

mail to the parties on the attached list.

 /s/ James E. Kane 

 James E. Kane 

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