IN THE UNITED STATES BANKRUPTCY COURT

EASTERN DISTRICT OF VIRGINIA

ALEXANDRIA DIVISION

IN RE: CASE NO.: 17-10074-KHK

ALICE JEAN VASKO, Debtor. Chapter 13

NOTICE

PLEASE TAKE NOTICE THAT SCOTT H. DONOVAN, Counsel for Debtor, has filed

papers with the Court to Object to Proof of Claim #4 .

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 on or before fifteen 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 a written response pursuant to Local Bankruptcy Rule 9013-

1(H)]. If you mail your request for 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.

Clerk of Court 

United States Bankruptcy Court

200 South Washington Street

Alexandria, VA 22314

You must also mail a copy to:

Thomas Gorman, Trustee Scott H. Donovan, Esquire

300 N Washington St #400 Attorney for Debtor

Alexandria, VA 22314 9402 Grant Avenue 

Manassas, VA 20110

Attend the hearing on the Motion scheduled to be held on JUNE 1, 2017

at 1:30 p.m. at United States Bankruptcy Court, 200 South Washington Street, 2 Floor, nd

Courtroom II, Alexandria, VA 22314.

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.

ALICE JEAN VASKO,

By Counsel

SCOTT H. DONOVAN, P.C.

 /s/Scott H. Donovan 

SCOTT H. DONOVAN, ESQUIRE

VSB #24592

Counsel for Debtor

9402 GRANT AVENUE

MANASSAS, VIRGINIA 20110

(703) 257-1159/ScottHDonovan@aol.com 

CERTIFICATE OF SERVICE

I hereby certify that on the 17 day of April, 2017, copies of the foregoing were th

electronically delivered to Thomas Gorman, Chapter 13 Trustee, US Trustee, Debtor and

mailed by USPS Certified Return Receipt requested to Judith Spagnuolo, Chairman of

General Municipal Authority of the Borough of Harveys Lake at 138 South Main Street,

Wilkes-Barre, PA 18703.

/s/Scott H. Donovan 

Scott H. Donovan, Esquire 

Case 16-14014-BFK Doc 31 Filed 04/17/17 Entered 04/17/17 14:58:52 Desc Main

 Document Page 1 of 2
IN THE UNITED STATES BANKRUPTCY COURT

EASTERN DISTRICT OF VIRGINIA

ALEXANDRIA DIVISION

IN RE: CASE NO.: 16-14014-KHK

ALICE JEAN VASKO, Debtor. Chapter 13

 

OBJECTION TO PROOF OF CLAIM #4

COMES NOW, Debtor, ALICE JEAN VASKO, by Counsel and moves this honorable

Court and objects to Proof of Claim #4 filed by General Municipal Authority of the Borough

of Harveys Lake (hereinafter “BORO”) for Municipal Sewage Fees Charged and states as

follows:

1. This Objection arises in and relates to Debtor’s Chapter 13 Bankruptcy case now

pending in this Court.

2. That on or about April 6, 2017, BORO filed Proof of Claim #4 for a secured claim

claim in the amount of $28,534.72, plus interest at the rate of 6%.

3. The Debtor does object to Proof of Claim #4 to the extent that BORO claims lawful

sewer charges, interest, Penalties, Sheriff’s Sale Costs and Poundage Deposit, Costs of Suit, Legal

fees and any post-petition charges as well.

4. That the Debtor has never been served with Notice of the Assessment of any of the

foregoing charges as required.

5. That the alleged aforementioned charges are unlawful, not due at this time and/or

are unreasonable and excessive, and not secured to the Real Estate as alleged.

6. The Debtor requests that the Proof of Claim filed by BORO be disallowed.

WHEREFORE, the Debtor respectfully requests that:

a) Proof of Claim #4 filed by BORO be disallowed, all or in part, and;

b) For such other and further relief as this Honorable Court deems just and proper

under the law.

ALICE JEAN VASKO,

By Counsel

SCOTT H. DONOVAN, P.C.

 /s/Scott H. Donovan 

SCOTT H. DONOVAN, ESQUIRE VSB #24592

9402 GRANT AVENUE

MANASSAS, VIRGINIA 20110

(703) 257-1159/ScottHDonovan@aol.com

CERTIFICATE OF SERVICE

I hereby certify that on the 17 day of April, 2017, copies of the foregoing were th

electronically delivered to Thomas Gorman, Chapter 13 Trustee, US Trustee, Debtor and

mailed by USPS Certified Return Receipt requested to Judith Spagnuolo, Chairman of

General Municipal Authority of the Borough of Harveys Lake at 138 South Main Street,

Wilkes-Barre, PA 18703.

/s/Scott H. Donovan 

Scott H. Donovan, Esquire 

Case 16-14014-BFK Doc 31 Filed 04/17/17 Entered 04/17/17 14:58:52 Desc Main

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