UNITED STATES BANKRUPTCY COURT 

FOR THE 

EASTERN DISTRICT OF VIRGINIA 

Alexandria Division 

In the Matter of: 

 Chapter 13 

CLARA ROBIN WILKERSON 

 Case No. 17-13280-KHK 

 

 Debtor 

OBJECTION TO CONFIRMATION OF PLAN, 

NOTICE OF OBJECTION TO CONFIRMATION OF PLAN 

AND 

NOTICE OF SCHEDULED HEARING ON THIS OBJECTION 

Thomas P. Gorman, Chapter 13 Trustee, has filed this objection to confirmation of 

your Chapter 13 Plan filed October 31, 2017. The cause for this objection is as 

follows: 

Violation of 11 U.S.C. §1325(b)(1)(B) - Disposable Income - Plan does not 

include step payment when car pays off in August, 2018. 

Violation of 11 U.S.C. §1325(a)(6) - Feasibility - 

-Failure to File Tax Returns at Time of 341. Debtor has not filed 2016 tax 

returns as of the time of his Meeting of Creditors. 

-Plan is underfunded as follows due to high filed mortgage Claim (Claim No. 

2): 

PERFORMANCE Amount of Plan Payment 180.00 x 6 

1,824.00 X 

54 

=1,080.00 

=98,496.00

Number of Months 

Total Receipts 99,576.00

 Disbursements Required 

Trustee 9,316.17 10.00%

Attorney 3951.00 

Taxes/Other Priority 31,301.76 

Secured 57,070.18 

Unsecured 838.80 83880.04x1%

Other 

 Total Disbursements 102,477.91

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Notice of Objection To Confirmation 

Clara Robin Wilkerson, Case # 17-13280-KHK 

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 wish 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 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 the date stated above. You must mail a copy to the 

persons listed below. 

Attend the hearing to be held on November 30, 2017 at 9:30 a.m., in 

Courtroom II on the 2nd floor, United States Bankruptcy Court, 200 South 

Washington Street, Alexandria, VA 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 

If you or your attorney do not take 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. 

Date: _November 9, 2017______ __/s/Thomas P. Gorman ________ 

 Thomas P. Gorman 

 Chapter 13 Trustee 

 300 N. Washington Street, #400 

 Alexandria, VA 22314 

 (703) 836-2226 

 VSB 26421 

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Notice of Objection To Confirmation 

Clara Robin Wilkerson, Case # 17-13280-KHK 

CERTIFICATE OF SERVICE 

I hereby certify that I have this 9th day of November, 2017, served via ECF to 

authorized users or mailed a true copy of the foregoing Objection to Confirmation, 

Notice of Objection and Notice of Hearing to the following parties. 

Clara Robin Wilkerson 

Chapter 13 Debtor 

17992 Swans Creek Lane 

Dumfries, VA 22026 

Tommy Andrews, Jr., Esq. 

Attorney for Debtor 

122 N. Alfred St. 

Alexandria, VA 22314 

 __/s/ Thomas P. Gorman______ 

 Thomas P. Gorman

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