C. Thomas Ebel, VSB No. 18637

William A. Gray, VSB No. 46911

SANDS ANDERSON PC

Post Office Box 1998

Richmond, Virginia 23218-1998

Telephone: 804.648.1636

Counsel for Bruce H. Matson, Chapter 7 Trustee

UNITED STATES BANKRUPTCY COURT

EASTERN DISTRICT OF VIRGINIA

Richmond Division

In re:

TERESA S. CAMDEN, Case No.: 16-31606-KRH

Chapter 7

Debtor.

TRUSTEE'S MOTION FOR APPROVAL

OF COMPROMISE AND SETTLEMENT

WITH DEBTOR AND CHRISTOPHER CAMDEN

Bruce H. Matson, Chapter 7 Trustee (“Trustee”) for the Bankruptcy Estate of Teresa S.

Camden ("Camden" or the "Debtor"), by counsel, files this motion for entry of an order pursuant

to Federal Rule of Bankruptcy Procedure 9019 approving the compromise and settlement of

claims between the Trustee, the Debtor, and Christopher Camden ("Mr. Camden")

(collectively, the "Parties"). In support of this motion, the Trustee respectfully represents as

follows:

Jurisdiction and Venue

1. This Court has jurisdiction over this Motion pursuant to 28 U.S.C. §§ 157 and

1334.

2. This matter is a core proceeding within the meaning of 28 U.S.C. § 157(b)(2).

3. Venue in this Court is proper under 28 U.S.C. §§ 1408 and 1409.

Background

4. On March 31, 2016 (the "Petition Date"), the Debtor filed a voluntary petition

under Chapter 7 of the Bankruptcy Code.

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5. The Trustee was appointed as interim trustee and continues to serve in that

capacity.

6. As of the Petition Date, the Debtor had an interest in the following assets:

(a) bank accounts at M & T Bank listed on the schedules in her Bankruptcy Case

which she held jointly with Mr. Camden being a personal checking account

number xx7074, and a money market savings account number xx5613 (together,

the "Joint Personal Accounts");

(b) an interest in tax refunds from both the Commonwealth of Virginia (in the amount

of $6,550.00) and the IRS (in the amount of $8,668.00) (together, the "Tax

Refunds") as set forth on the joint 2015 Income Tax Returns of the Camdens

which the Debtor provided to the Trustee;

(c) all of the interest in Commonwealth Sports Medicine, P.C., a Virginia

Professional Corporation ("CSM"), and Brennan's Aesthetics, LLC, a Virginia

limited liability company ("BA") (together with CSM, the "Entities"); and

(d) certain real property in Henrico County, Virginia, owned as tenants by the entirety

with right of survivorship with Mr. Camden, commonly known as 12124

Blairmont Court, Glen Allen, Virginia 23059 and identified as tax map number

737-772-7112 (the “Real Property”), which was conveyed to the Camdens by a

certain Deed of Gift from the Debtor to the Camdens dated November 10, 2015,

and recorded November 12, 2015 in the Clerk's Office of the Circuit Court of

Henrico County, Virginia in Deed Book 5424, page 2187.

7. Based on the nature and timing of conveyance of the Real Property from the

Debtor to the Debtor and Mr. Camden, the Trustee has claimed the conveyance is voidable, that

the Trustee has an interest in the Real Property and any equity of the Debtor is not exempt to the

extent claimed by the Debtor on her schedules in her Bankruptcy Case.

8. While Mr. Camden may have an interest in the Joint Personal Accounts and the

Tax Refunds, the Trustee has claimed the entire amount of the Joint Personal Accounts and the

Tax Refunds belong to the Trustee for the benefit of the Debtor's bankruptcy estate.

9. As of the date of the Settlement Agreement defined below, both Entities were no

longer operating and the existence of both has been terminated with the Virginia State

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Corporation Commission. The Entities owned various assets (the "Entity Assets"), including

equipment and certain bank accounts at M & T Bank (the "Entity Bank Accounts"). The

Entities also owed certain creditors including secured creditors who have claimed a lien on

certain of the Entity Assets, but the Trustee believes there may be value for the Debtor's

bankruptcy estate in taking control of the Entities and/or the Entity Assets.

10. Any known creditors that may assert claims against the Entities have been

provided notice of this motion.

11. The Trustee believes the resolution of the competing issues as provided by the

proposed settlement is in the best interest of the creditors.

Settlement Terms

12. The Parties have engaged in good faith, arms’ length negotiations in an effort to

resolve their claims and defenses related to the Joint Personal Accounts, the Tax Refunds, the

Entities, the Entity Assets, the Entity Bank Accounts, and the Real Property. Without conceding

the merits of any claim or argument asserted by any other Party, the Parties have entered into a

Settlement Agreement ("Settlement Agreement"), attached hereto as Exhibit A, in order to

avoid the inherent risk, delay, and substantial expense that would arise from litigating all claims

and defenses related to the property described herein.

13. Under the terms of the proposed compromise and settlement, the Debtor and Mr.

Camden have agreed to, and done the following1:

1) agreed to pay, and have paid over to the Trustee the balance of the Joint

Personal Accounts totally $73,987.54 as follows:

a. M & T Bank account number x7074 in the amount of $8,305.58.

b. M & T Bank Account number x5613 in the amount of $65,681.96

1

The Settlement Agreement contains all terms and conditions of the settlement, and control over any inconsistencies

between the description of the agreement herein, and the actual Settlement Agreement.

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2) agreed to pay, and have paid over to the Trustee the following Tax

Refunds in the total amount of $15,218.00 (which were deposited to and

are a part of the Joint Personal Accounts paid over to the Trustee):

a. Virginia Income Tax Refund in the amount of $6,550.00

b. Federal Income Tax Refund in the amount of $8,668.00; and;

3) agreed to pay, and have paid over to the Trustee the balance of the

following Entity Bank Accounts:

a. M & T Bank CSM account number x6898 in the amount of $12,691.21

b. M & T Bank BA account number x7094 in the amount of $42,941.99.

14. In addition, the Trustee, the Debtor and Mr. Camden wish to settle any and all

issues between them with respect to any interest the Trustee may have in the Real Property in

return for payment by the Debtor and Mr. Camden of the amount of $25,000 to the Trustee,

which amount has been paid by the Debtor to the Trustee.

Relief Requested

15. The Trustee, in his business judgment, believes the compromise and settlement as

detailed in the Settlement Agreement, is in the best interest of the estate, and is fair and equitable

to the creditors of the estate.

16. The Trustee requests that the Court approve the Settlement Agreement, and

authorize the Trustee to take any actions necessary to fulfill the same.

Points and Authorities

17. The well-established law encourages the approval of settlements to help resolve

bankruptcy cases. Specifically, in In re Martin, 91 F.3d 389 (3d Cir. 1996), the United States

Court of Appeals for the Third Circuit stated that "[t]o minimize litigation and expedite the

administration of a bankruptcy estate, compromises are favored in bankruptcy." Id. at 393, see

also In re Frye, 216 B.R. 166, 170 (Bankr. E.D. Va. 1997) ("Bankruptcy Rule 9019 governs

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compromise of a claim and permits a trustee to compromise or settle controversies to avoid the

time and expense of litigating controversial claims.").

18. In determining whether to approve a compromise and settlement, the Court must

look at various factors and determine whether the compromise is in the best interest of the estate

and whether it is fair and equitable to the creditors of the estate. In re Frye, 216 B.R. 166, 174

(Bankr. E.D. Va. 1997). These factors include: (1) the probability of success in litigation; (2) the

potential difficulties, if any, in collection; (3) the complexity of the litigation involved and the

expense, inconvenience and delays necessarily attending it; and (4) the paramount interest of the

creditors. Id.

19. Approval of the Settlement is warranted because it provides for a resolution of all

disputes regarding the Joint Personal Accounts, the Tax Refunds, the Entities, the Entity Assets

and the Real Property. The Trustee believes that the approval of the compromise and settlement

is in the best interest of the estate and should be approved.

WHEREFORE, the Trustee prays that the Court enter an order substantially in the form

attached hereto as Exhibit B; and granting the Trustee such other and further relief as is just and

proper.

Respectfully submitted, this 7th day of November, 2016.

/s/ C. Thomas Ebel

C. Thomas Ebel, VSB No. 18637

William A. Gray, VSB No. 46911

SANDS ANDERSON PC

Post Office Box 1998

Richmond, Virginia 23218-1998

Telephone: 804.648.1636

Counsel for Bruce H. Matson, Chapter 7 Trustee

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SETTLEMENT AGREEMENT

This SETTLEMENT AGREEMENT (this "Agreement") is made thi^Jday

October, 2016, by and between Bruce L. Matson, Esquire, as Chapter 7 Trustee (the " Trustee") for the Bankruptcy Estate of Teresa S. Camden; and Teresa S. Camden (the

"Debtor") and Christopher Camden, the husband of the Debtor (" Mr. Camden" and

collectively with the Debtor, the "Camdens", and collectively the Chapter 7 Trustee and

the Camdens are the "Parties": each a "Party").

of

RECITALS

A. On March 31, 2016 (the "Petition Date"), the Debtor filed with the

United States Bankruptcy Court for die Eastern District ofVirginia, Richmond Division

(the "Court"), a voluntary petition seeking relief pursuant to chapter 7 of title 1 1 of the

United States Code (the "Code"), to which case number 16 -31606-KRH has been

assigned (the "Bankruptcy Case'*).

B. The Trustee was appointed as interim trustee in the Bankruptcy Case and

continues to serve in that capacity

C. As ofthe Petition Date, the Debtor had an interest in certain bank accounts

at M & T Bank listed on the schedules in her Bankruptcy Case which she held jointly

with Mr. Camden being a personal checking account number x7074 and a money market

savings account number x5613 (together, the "Joint Personal Accounts")

D. As of the Petition Date, the Debtor listed on her schedules in her

Bankruptcy Case an interest in tax refunds from both the Commonwealth ofVirginia (in

the amount of $6550.00) and die IRS (in the amount of $8668.00) (together, the "Tax

Refunds") as set forth on the joint 2015 Income Tax Returns of the Camdens which the

Debtorprovided to the Trustee.

E. As of the Petition Date, the Debtor owned all of the interest in

Commonwealth Sports Medicine, P. C.} A Virginia Professional Corporation ("CSM")

and Brennan's Aesthetics, LLC, a Virginia limited liability company ("BA" and together

with CSM the "Entities") . As ofthe date ofthis Agreement, both Entities are no longer

operating and the existence of both has been terminated with the Virginia State

Corporation Commission.

As of the Petition Date, the Entities owned various assets (the "Entity

Assets"), including equipment and certain bank accounts at M & T Bank (the "Entity

Bank Accounts"). The Entities owe certain creditors including secured creditors who

have claimed a lien on certain ofthe Entity Assets, but the Trustee believes there may be

value for the Debtor's bankruptcy estate in taking control ofthe Entities and/or the Entity

Assets.

F.

EXHIBIT A

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G. As of the Petition Date, the Camdens owned as tenants by the entirety

with right of survivorship certain real property in Henrico County, Virginia, commonly

known as 12124 Blainnont Court, Glen Allen, Virginia 23059 and identified as tax map

number 737-772-7112 (the "Real Property"), which was conveyed to the Camdens by a

certain Deed of Gift from the Debtor to the Camdens dated November 10, 2015, and

recorded November 12, 2015 in the Clerk's Office of the Circuit Court of Henrico

County, Virginia in Deed Book 5424, page 2187.

H. While Mr. Camden has an interest in the Joint Personal Accounts and the

Tax Refunds, the Trustee has claimed the entire amount ofthe Joint Personal Accounts

and the Tax Refunds belongs to the Trustee for the benefit of the Debtor's bankruptcy

estate.

I. While the Camdens have claimed they are owed certain funds by the

Entities and that the Debtor may have a continuing interest in the Entities, the Trustee has

denied they are owed any amounts by the Entities and that the Debtor has any further

interest in the Entities, and the Trustee has taken or wishes to take possession and control

ofthe Entities and the Entity Assets for the benefit of the Debtor's bankruptcy estate and

the Debtor is agreeable to the Trustee doing so.

J. Based on the nature and timing of conveyance of the Real Property from

the Debtor to the Debtor and Mr. Camden, the Trustee has claimed the conveyance is

voidable, that the Trustee has an interest in the Real Property and any equity of the

Debtor is not exempt to the extent claimed by the Debtor on her schedules in her

Bankruptcy Case.

K. The Trustee and The Debtor and Mr. Camden wish to resolve the issues

between them with respect to the assets ofthe Debtor described in this Agreement and

with respect to the Entities and the Entity Assets, and in that regard, as ofthe date ofthis

Agreement, the Debtor and/or Mr. Camden have done the following:

1) agreed to pay and have paid over to the Trustee the balance of the

Joint Personal Accounts totally $73,987.54 described as follows:

a M & T Bank account number x7074 in the amount of

$8,305.58.

b. M & T Bank Account number x5613 in the amount of

$65,681.96

2) agreed to pay and have paid over to the Trustee the following Tax

Refunds in the total amount of$15,218.00 (which were deposited to and are a part

ofthe Joint Personal Accounts paid over to the Trustee):

a, Virginia Income Tax Refund in the amount of$6550.00

b. Federal Income Tax Refund in the amount of$8668.00

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3) have agreed to pay and have paid over to die Trustee the balance ofthe

following Entity Accounts:

a.M&T Bank CSM account number x6898 in the amount of $12,691 .21

b. M & T Bank BA account number x7094 in the amount of$42,941.99.

The Trustee and the Debtor and Mr. Camden wish to settle any and all

issues between them with respect to any interest the Trustee may have in the Real

Property in return for payment by the Debtor and Mr. Camden ofthe amount of $25,000

to the Trustee, which amount has been paid by the Debtor to the Trustee.

The Parties have engaged in good faith, arms' length negotiations in an

effort to resolve various claims and defenses of the Parties in the Bankruptcy Case,

resulting in the settlement that is set forth in this Agreement. In particular, the Parties

have reached a compromise and settlement ofthe issues, controversy, or disputes related

to the claims and defenses as to the Joint Personal Accounts, the Tax Refunds, the

Entities and the Entity Assets, and the Real Property. Without conceding the merits of

any claim or argument asserted by any other Party, the Parties have entered into this

Agreement in order to avoid the inherent risk, delay, and substantial expense that would

arise from litigation in the Bankruptcy Case.

L.

M.

AGREEMENT

NOW THEREFORE, in consideration of the above Recitals, each of which

being true and correct and incorporated herein by reference, and of the promises,

covenants, and representations hereinafter made, and for other good and valuable

consideration, the receipt and sufficiency ofwhich are hereby acknowledged, the Parties

do hereby mutually agree as follows: . Court Approval. This Agreement shall be ofno force or effect unless and

until both a final order of the Court approving this Agreement (the "Order") has been

entered and is no longer appealable. The Trustee and his counsel shall take all actions

reasonably necessary or required to obtain Court approval of this Agreement, and the

Debtor, her counsel and Mr. Camden will provide any assistance reasonably necessary to

aid the Trustee in completion of such actions. In the event that this Agreement is not

approved by the Court or the Order approving this Agreement is reversed by a court of

competent jurisdiction, then tins Agreement shall be deemed null and void ab initio, in

which case all rights and arguments of each Party shall be reserved. In the event that this

Agreement shall become null and void, then neither the terms nor the statements

contained in this Agreement, nor in any motion or motions filed seeking the entry ofthe

Order, nor in any correspondence related to the negotiation, drafting, or approval of this

Agreement, shall be argued or deemed to be an admission against any Party's interest,

nor shall any such statement in any way enhance or diminish the rights of any Party

hereto. Upon entry of the Order approving this Agreement and no appeal having been

filed and the Order is no longer appealable, the Parties will cooperate in implementing all

terms and conditions ofthis Agreement.

1.

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2. Turnover of Joint Personal Accounts. The Camdens have turned over

to the Trustee the full balance of the Joint Personal Accounts totaling $ 73,987.74 as

follows;

a. M & T Bank account number x7074 in lite amount of$8,305.58.

b. M & T Bank Account number x5613 in the amount of$65,681 .96

The Trustee does hereby accept such amounts in full settlement of any and all claims

which the Trustee may have against the Camdens with respect to the Joint Personal

Accounts. The Camdens do hereby release any and all interest or claims which they may

have in the Joint Personal Accounts.

3. Turnover of Tax Refunds. The Camdens have turned over to the Trustee

the full amount ofOre Tax Refunds totaling $15,218.00 (which were deposited to and are

a part ofhe JointPersonal Accounts paid over to the Trustee) as follows:

a. Virginia Income Tax Refund in the amount of $6550.00

b. Federal Income Tax Refund in the amount of$8668.00

The Trustee does hereby accept such amount in full settlement of any and all claims

which he Trustee may have against the Camdens with respect to he Tax Refunds. The

Camdens do hereby release any and all interest or claims which they may have in he Tax

Refunds.

4. The Entities and the Entity Assets. The Debtor has and does hereby

turnover and release unto he Trustee any and all interest he Debtor may have in he

Entities and the Entity Assets including without limitation he Entity Accounts, which

accounts are follows:

a, M&T Bank CSM account number x6898 in die amount of $12,691.21

b. M&TBank BA account number x7094 in he amount of$42,941.99

The Debtor acknowledges and agrees that the Trustee shall have full and complete

authority to lake all action which he Trustee may deem necessary, in his sole discretion,

with respect to he Entities and he Entity Assets, including without limitation

abandoning to secured creditors any Entity Assets in which such creditor may claim a

lien, payment of such creditors of the Entities as the Trustee deems appropriate,

distributing he Entity Assets in such manner as he Trustee deems appropriate and taking

such other action as he Trustee deems appropriate with respect to he Entities, including

liquidation and dissolution. The Debtor and Mr. Camden each do hereby release and

forever discharge any and all claims they may have against he Entities and he Entity

Assets, including without limitation he release of any claims for salary, wages oar other

compensation or payment for services. The Debtor acknowledges hat the Trustee intends

to enter a separate related Settlement Agreement with Direct Capital Corporation ("Direct

Capital") whereby the Trustee shall abandon and release to Direct Capital certain

equipment and a bank account ofCSM in which Direct Capital claims a security interest

in return for certain agreements from Direct Capital, including he release ofany interest

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in the BA Entity Bank Account and the modification of its proof of claim in Debtor's

Bankruptcy case. The Debtor agrees with and will not object to the terms of such

settlement and will co-operate with die Trustee and Direct Capital in the turn over to

Direct Capital of any equipment or other Entity Assets in the possession of the Debtor

which die Trustee abandons and directs be turned over to Direct Capital or any other

secured creditor ofCSM, BA or the Debtor.

5. The Real Property. Hie Debtor has paid to the Trustee and the Trustee

does hereby accept the amount of $25,000 in full settlement of all claims which die

Trustee may have in or against the Real Property. The Trustee does hereby release and

forever discharge unto the Camdens, and their heirs, personal representatives, successors

and assigns any and all claims against or interest in the Real Property which die Trustee

may have.

6. Limited Releases:

a. Except for the terms, covenants, conditions, and requirements in this

Agreement, the Trustee, for himself and the Debtor's chapter 7

bankruptcy estate and his representatives, agents, trustees, successors

and assigns, and any other entity claiming by or through him, hereby

releases, and forever discharges, jointly, severally and otherwise, Mr.

Camden and his heirs, personal representatives, trustees, agents,

insurers, attorneys, successors and assigns, and any other person or

entity claiming by or through Mr. Camden of and from any and all

claims, demands, damages, actions, costs, expenses, actions, causes of

action, suits at law or in equity, in connection with the Joint Personal

Accounts, the Tax Refunds, the Entities, the Entity Assets and die Real

Property.

b. Except for the terms, covenants, conditions, and requirements in this

Agreement, die Camdens, for themselves and their heirs, personal

representatives, trustees, agents, successors and assigns, and any other

person or entity claiming by or through them, hereby release, and

forever discharge, jointly, severally and otherwise, the Trustee and the

Debtor's bankruptcy estate, and their heirs, personal representatives,

trustees, agents, insurers, attorneys, successors and assigns, and any

other person entity claiming by or through die Trustee of and from any

and all claims, demands, damages, actions, costs, expenses, actions,

causes of action, suits at law or in equity, in connection with the Joint

Personal Accounts, the Tax Refunds, the Entities, die Entity Assets,

and the Real Property, including without limitation forever waiving

and releasing (i) any interest they may have in the Joint Personal

Accounts, the Tax Refunds, the Entity Assets, (ii) any claim against

the Entities or the bankruptcy estate of the Debtor for any debt or

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liability whatsoever and (iii) any right to file a proof of claim in the

Bankruptcy Case.

e. For the avoidance of doubt, any claims, demands, damages, actions,

costs, expenses, causes of action, suits at law or in equity that are not

expressly released in this Limited Mutual Release shall survive this

Agreement.

Default: The occurrence of any of the following shall constitute an

"Event ofDefault" under this Agreement*

a. The failure of any Party so obligated to observe or perform fully and

timely any obligation, term, provision, covenant, or agreement

contained in this Agreement, which is not cured within ten (10)

business days of receipt by the defaulting Party of written notice of

such default; or

b. Any ofthe representations and warranties provided herein by aParty is

determined, after notice and a hearing, to have been false or materially

inaccurate when made.

7.

8. General Terms:

a. Recitals. The Parties agree that the above recitals are true, that they

are an important part ofthe consideration for this Agreement, and that

they are incorporated herein by this reference.

b. Counterparts. This Agreement may be executed in two or more

counterparts, including by facsimile or pdf each of which shall for all

purposes be deemed to constitute an original, but all of which, when

taken together, shall constitute but one instrument, and shall become

effective when copies hereof, when taken together, bear the signatures

ofeach ofthe Parties hereto.

c. Disputes And Remedies. To the extent allowable by law, the United

States Bankruptcy Court for Eastern District of Virginia, Richmond

Division shall have and retain exclusive jurisdiction to adjudicate any

dispute that arises from, arises out of or is related to this Agreement

and to interpret, implement, and enforce the terms of this Agreement,

including the resolution of any dispute arising under the Order

approving this Agreement.

nra PARTIES WAIVE TRIAL BY JURY OF ANY ANP ALL

DISPUTES OR ISSUES AND AGREE THAT ALL SUCH

MATTERS SHALL BE TRIED AND Dff.cmP.n SOT.F.I ,Y BY A

JUDGE SITTING WITHOUT A JURY.

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d. Controlling Law. The performance and construction of this

Agreement, to the extent not governed by tide 11 ofdie United States

Code, shall be governed in all respects by the laws of the

Commonwealth of Virginia without regard to its conflicts of laws

provisions. . e. Remedies. Upon the occurrence of an Event of Default, the nondefaulting Party or Parties shall have the rights and remedies they may

have pursuant to applicable law, all such rights being cumulative and

enforceable alternatively, successively, or concurrently. Provided

further, that the releases contained in Section 6 above shall survive an

Event of Default hereunder, including as to the defaulting Party,

except to the extent that a Party's representations or warranties

hereunder were false or inaccurate when made, to be determined after

notice and a hearing.

f. Severability. Ifany term, provision, or condition, or any part thereof,

of this Agreement shall for any reason be found or held invalid or

unenforceable by any state or federal court or governmental agency of

competent jurisdiction, such invalidity or unenforceability shall not

affect the remainder of such term, provision, or condition, nor any

other term, provision or condition, and this Agreement shall survive

and be construed as if such invalid or unenforceable term, provision,

or condition bad not been contained therein, but only to the extent of

such invalidity or unenforceability.

g. Further Assurances. The Parties agree to execute any and all

documents necessary to consummate the settlement between the

Parties and to otherwise exercise reasonable efforts to facilitate the

terms ofthe settlement between the Parties.

h. Advice Of Counsel. The Parties hereby acknowledge that they have

had the opportunity to obtain the advice of experienced counsel of

their own choosing in connection with the negotiation and execution of

this Agreement and to obtain such counsel's advice on the matters

herein including, without limitation, the provisions for waiver of trial

by jury. The usual rule of construction that any ambiguities are to be

resolved against the drafting party shall be inapplicable in the

construction and interpretation of this Agreement as well as any

amendments or exhibits thereto

i. No Third Party Beneficiaries. This Agreement is intended neither to

enlarge nor diminish, in any regard, the rights ofany entity not a party

to the Agreement There are no third-party beneficiaries of this

Agreement, either intended or unintended.

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j. Headings Not Part Of Agreement. The headings contained in this

Agreement are inserted for convenience of reference and are not

intended to be a part ofor to affect the meaning or interpretation ofthe

Agreement. .

k. Entire Agreement. This Agreement sets forth the entire agreement

between the Parties regarding the subject matter hereof and fully

supersedes any and all conflicting prior communications, agreements,

or understandings between the Parties, written or oral.

1. Amendments Only In Writing. The terms ofthis Agreement may be

changed only by a writing executed by all Parties, which may also

require approval ofthe Court.

m. Successors And Assigns, this Agreement, and all provisions hereof

shall inure to the benefit of and be binding upon fire Parties hereto,

their successors in interest, and their assigns, even ifthe Bankruptcy

Case is dismissed Or converted to a case under a different chapter of

die Code.

n. Notices. Any notice or other communication required or permitted by

this Agreement contemplated hereby shall be in writing and may be

delivered: (i) personally, (ii) by first class mail, (it) by express mail or

(iv) by e-mail or facsimile ifalso sent not later than the next business

day by one ofthe other means provided for in tins Section, as follows:

Ifto the Debtor: Teresa S. Camden

12124 Blairmont Court,

(Hen Allen, Virginia 23059

with a copy to:

Sharon Stuart , Esq.

Stuart Law Firm, IXC

2222 Monument Avenue

Richmond, Virginia 23220

scstuart@sharonstuart.com

Ifto Mr. Camden: Christopher Camden

12124 Blairmont Court,

Glen Allen, Virginia 23059

Ifto the Trustee: Bruce L. Matson, Esq.

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LeCIair Ryan

91 9 East Main Street, 24th Floor

Richmond, Virginia 23219

bruce.matson@leclairryan.com

with a copy to:

C. Thomas Ebel, Esq.

Sands Anderson PC

P.O. Box 1998

11 1 1 East Main Street, Suite 2300 (23219)

Richmond, Va. 23218-1998

tebel@sandsanderson.com

{REMAINDER OF PAGE INTENTIONALLY LEFT BLANK]

[SIGNATURE PAGES FOLLOW]

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SIGNATURE PAGE TO SETTLEMENT AGREEMENT

IN WITNESS WHEREOF, the undersigned have executed this Agreement as of

the day and year written below. •

Date: /o • M A

TERESA S. CAMDEN

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SIGNATURE PAGE TO SETTLEMENT AGREEMENT

Date: /< M<(j>

BRUCEL. MATSON, Chapter 7

Trustee for theBankruptcy Estate of

Teresa S. Camden

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SIGNATURE PAGE TO SETTLEMENT AGREEMENT

Date: /0 ~3 0 "^/C

CHRISTOPJ CAMDEN

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EXHIBIT B

C. Thomas Ebel, VSB No. 18637

William A. Gray, VSB No. 46911

SANDS ANDERSON PC

Post Office Box 1998

Richmond, Virginia 23218-1998

Telephone: 804.648.1636

Counsel for Bruce H. Matson, Chapter 7 Trustee

UNITED STATES BANKRUPTCY COURT

EASTERN DISTRICT OF VIRGINIA

Richmond Division

In re:

TERESA S. CAMDEN, Case No.: 16-31606-KRH

Chapter 7

Debtor.

ORDER APPROVING COMPROMISE

AND SETTLEMENT WITH DEBTOR AND CHRISTOPHER CAMDEN

Before the Court is the Trustee's Motion for Approval of Compromise and Settlement

with Debtor and Christopher Camden (the "Motion") in which the Chapter 7 Trustee seeks

approval of a compromise and settlement of claims held by and between Debtor Teresa S.

Camden, Christopher Camden, and the Trustee. Upon consideration of the Motion,

IT IS ORDERED that the Motion is GRANTED;

IT IS ORDERED that the compromise and settlement between the Debtor, Mr. Camden

and the Trustee, and the Settlement Agreement2is APPROVED;

IT IS ORDERED that the Trustee is authorized to take all actions, and execute any

documentation necessary to effectuate the Settlement Agreement.

1 Unless otherwise defined herein, capitalized terms in this Order shall have the meaning ascribed to them in the

Motion.

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Date:

KEVIN R. HUENNEKENS, JUDGE

UNITED STATES BANKRUPTCY COURT

Entered on Docket:

For this we ask:

/s/ C. Thomas Ebel

C. Thomas Ebel, VSB No. 18637

William A. Gray, VSB No. 46911

SANDS ANDERSON PC

Post Office Box 1998

Richmond, Virginia 23218-1998

Telephone: 804.648.1636

Counsel for Bruce H. Matson, Chapter 7 Trustee

Seen and agreed:

/s/

Sharon Choi Stuart, VSB No. 45026

Stuart Law Firm, LLC

2222 Monument Avenue

Richmond, VA 23220

Counsel for Teresa S. Camden

L.B.R. 9022-1(C) CERTIFICATION

I hereby certify that the foregoing proposed order has been endorsed by all necessary

parties.

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COPIES TO:

Sharon Choi Stuart, Esquire

Stuart Law Firm, LLC

2222 Monument Avenue

Richmond, Virginia 23220

Counsel for the Debtor

Bruce H. Matson, Esquire

919 East Main Street, 24th Floor

Richmond, VA 23219

Chapter 7 Trustee

C. Thomas Ebel, Esquire

William A. Gray, Esquire

SANDS ANDERSON PC

P.O. Box 1998

Richmond, VA 23218-1998

Counsel to Chapter 7 Trustee

Robert B. Van Arsdale, Esquire

Office of the U.S. Trustee

701 East Broad Street, Room 4304

Richmond, VA 23219

Office of the US Trustee

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