IN THE UNITED STATES BANKRUPTCY COURT

FOR THE EASTERN DISTRICT OF VIRGINIA

Richmond Division

_________________________________________

In re: John Daniel Mangigian, Jr. )

) Case No. 16-35630

) Chapter 13

Debtor. ) Trustee: Roy M. Terry

)

_________________________________________ )

DEBTOR'S OBJECTION TO PROOF OF CLAIM # 9

The Debtor, John Daniel Mangigian, Jr., by counsel, Nupa Agarwal, Esq., objects 

to the Proof of Claim filed by Federal National Mortgage Association, in the amount of 

$145,502.37 for a pre-petition debt, and assigns the following reasons for the same:

1. Debtor filed a Chapter 13 Bankruptcy on November 16, 2016; and converted to a 

Chapter 7 on November 13, 2018.

2. Federal National Mortgage Association filed its Proof of Claim on May 1, 2019; 

and Amended Claim on May 7, 2019.

3. Debtor’s Counsel Objects to this Proof of Claim as Federal National Mortgage 

Association has not shown supporting documents that Debtor was listed on the 

Mortgage. Debtor states he was only on the Deed.

WHEREFORE, Debtor respectfully requests that this Honorable Court disallow 

the Proof of Claim # 9 filed by Federal National Mortgage Association and grant such 

other and further relief as is just and proper.

NOTICE UNDER LOCAL BANKRUPTCY RULE 3007-1, UNLESS A 

WRITTEN RESPONSE AND A REQUEST FOR HEARING ON THIS OBJECTION 

ARE FILED WITH THE CLERK OF THE COURT AND SERVED ON THE 

OBJECTING PARTY AND THE TRUSTEE WITHIN 30 DAYS OF THE SERVICE 

OF THIS OBJECTION, THE COURT MAY DEEM ANY OPPOSITION WAIVED, 

Case 16-35630-KLP Doc 103 Filed 05/20/19 Entered 05/20/19 19:42:24 Desc Main

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TREAT THE OBJECTION AS CONCEDED, AND ENTER AN ORDER GRANTING 

THE REQUESTED RELIEF WITHOUT A HEARING.

/s/ John Daniel Mangigian, Jr.

Debtor

By: /s/ Nupa Agarwal

Nupa Agarwal

 Counsel for Debtor

 VA. State Bar No. 42545

PO Box 17275

 Richmond, VA 17275

TEL:(804) 691-2655

PROOF OF SERVICE

I certify that I have this 20th Day of May 2019 transmitted a true copy of the foregoing application 

electronically through the Court‘s CM/ECF system or by mail to the Debtor, John Daniel Mangigian, Jr.,

2025 Rocky Ford Road, Powhatan, VA 23139; Chapter 7 Trustee, the United States trustee and to all necessary 

parties, on the mailing matrix maintained by the clerk of court. 

/s/Nupa Agarwal

 Nupa Agarwal

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IN THE UNITED STATES BANKRUPTCY COURT

FOR THE EASTERN DISTRICT OF VIRGINIA

Richmond Division

_________________________________________

In re: JOHN DANIEL MANGIGIAN, JR. )

) Case No. 16-35630

) Chapter 7

Debtor. ) Trustee: Roy M. Terry

)

_________________________________________ )

NOTICE OF OBJECTION TO CLAIM # 9

Debtor’s Counsel has filed an objection to the proof of claim #9 by Federal National 

Mortgage Association (the “Objection”).

Your claim may be reduced, modified, or eliminated. You should read these papers 

carefully and discuss them with your attorney, if you have 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 motion, then you or your attorney must:

File with the court, at the address below a written response to the objection and a request 

for hearing within 30 days of filing of this motion. Unless a written response is filed and 

served by the date specified, the Court may decide that you do not oppose the objection to your 

claim. If you mail your response to the court for filing, you must mail it early enough so that the 

court will receive it on or before the date stated above.

Clerk of Court 

U.S. Bankruptcy Court 

701 E. Broad Street, St. 4000 

Richmond, VA 23219 

You must also mail a copy to:

Nupa Agarwal

VA. State Bar No. 42545

PO Box 17275

Richmond, VA 17275

TEL:(804) 691-2655

Case 16-35630-KLP Doc 103 Filed 05/20/19 Entered 05/20/19 19:42:24 Desc Main

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Federal National Mortgage Association Inc

c/o Brad Geisen of Active Data Technologies

1095 Broken Sound Parkway

Suite 100

Boca Raton, FL 33487

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

objection to your claim and may enter an order granting that relief.

Date: May 20, 2019

/s/ Nupa Agarwal,Esq.

VA. State Bar No. 42545

 P.O. Box 17275

Richmond, VA 23226

 TEL: 804-691-2655

PROOF OF SERVICE

I certify that I have this 20th Day of May 2019 transmitted a true copy of the foregoing application 

electronically through the Court‘s CM/ECF system or by mail to the Debtor, John Daniel Mangigian, Jr., 2025 Rocky 

Ford Road, Powhatan, VA 23139; Chapter 7 Trustee, the United States trustee and to all necessary parties, on the 

mailing matrix maintained by the clerk of court. 

/s/Nupa Agarwal, Esq

 Nupa Agarwal

 Counsel for Debtor

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