Yvonne Cochran, VSBN 26015

COCHRAN LAW FIRM, P.C.

4509 West Broad Street

Richmond, VA 23230 

(804) 358-2222

Counsel for Debtor

UNITED STATES BANKRUPTCY COURT

EASTERN DISTRICT OF VIRGINIA

Richmond Division

In re: Barbara A. Sledge, )

)

)

)

Case No. 16-34399-KRH

Debtor. Chapter 13

MOTION FOR APPROVAL OF LOAN MODIFICATION

COMES NOW Barbara A. Sledge, (the “Debtor”), by counsel, and in support of this

Motion to Approve Loan Modification Agreement (hereinafter “Motion”) alleges and states as 

follows:

1. On or about 9/2/2016, the Debtor filed a voluntary petition for relief under Chapter 13 of the 

United States Bankruptcy Code, and Suzanne E. Wade was appointed Trustee of the Debtor’s 

estate.

2. At the time of filing of the bankruptcy petition for relief the Debtor owned a parcel of real 

estate commonly known as 3531 Dorset Road, Richmond, VA 23234, (the “Property”) and is 

more particularly described as follows:

TAX MAP PARCEL ID #: C008-0750/010

3. The Property is encumbered by a first deed of trust dated 8/30/2007, (the “Deed of Trust”), 

which Deed of Trust secures payment of a promissory note to (the “Note”). A copy of the 

recorded Deed of Trust and Note are attached hereto as Exhibit “1.”

Case 16-34399-KRH Doc 23 Filed 09/08/17 Entered 09/08/17 15:55:15 Desc Main

 Document Page 1 of 10
Yvonne Cochran, VSBN 26015

COCHRAN LAW FIRM, P.C.

4509 West Broad Street

Richmond, VA 23230 

(804) 358-2222

Counsel for Debtor

Original Note & D/T Terms Modified Note & D/T Terms

1. Original Principal Balance $144,973.93 1. New Principal Balance $192,693.34

2. Current principal Balance $180,373.29 2 Arrearages, Fees, Costs

3 Current Interest rate 10.308 3. New Interest Rate 4.75

4 Current Monthly Payment

P&I

$1,691.54 4. New Monthly Payment P&I $1,230.02

5 Current Maturity Date 12/1/2037 5. New Maturity Date 12/2/2037

6. New payment Start Date 8/1/2017

6 On or about 1/17/2017, the Lender filed a Proof of Claim, a copy of which is attached 

hereto as Exhibit “2,” stating as follows: 

a. The amount of the principal balance is $180,373.29 (Current Principal Balance). 

b. The current monthly payment is $1,691.54 (principal and interest).

c. The current fixed interest rate is 10.308% per annum. 

d. The current Maturity Date is 12/1/2037.

7 The Debtor believes it to be in her best interest to modify the terms of the Note and 

Deed of Trust pursuant to the terms of the Loan Modification Agreement (the “Loan 

Case 16-34399-KRH Doc 23 Filed 09/08/17 Entered 09/08/17 15:55:15 Desc Main

 Document Page 2 of 10
Yvonne Cochran, VSBN 26015

COCHRAN LAW FIRM, P.C.

4509 West Broad Street

Richmond, VA 23230 

(804) 358-2222

Counsel for Debtor

Modification Agreement”). A copy of the Loan Modification Agreement is attached 

hereto as Exhibit “3” (Fully Executed Loan Modification Agreement).

a. The specific terms of the Loan Modification Agreement are as follows:

Under the terms of the Loan Modification Agreement, the new amount payable 

under the terms of the Note and Deed of Trust will be $192,693.34 (the “New 

Principal Balance”). The Principal Balance shall consist of the unpaid interest, 

escrow advances, arrears and fees (excluding late charges) past due as of the 

Modification Effective Date . The new monthly payment starting on August 1, 

2017 and ending December 2, 2037 is $1,230.20 (principal and interest). The 

monthly payment including principal and interest, taxes and insurance is $1,446.74.

b. The new interest rate is a fixed rate of 4.75% per annum for 60 months. This 

4.75% interest rate commenced on August 1, 2017 and will end on December 2,

2021.

c. The new maturity date is 12/2/2037, (the “Maturity Date”).

d. Debtor will be required to make regular monthly payments under the terms of 

the Loan Modification Agreement commencing on 8/1/2017, and on the first 

(1st) day of each month thereafter as the payments become due.

8 The Debtor does not intend to change the amount of her monthly Chapter 13 Plan 

payments as a result of the monthly mortgage payment being adjusted under the terms of 

the Loan Modification Agreement.

9 In the event that the Debtor defaults under the terms of the Loan Modification 

Agreement, the lien holder retains its rights under the Note secured by the Deed of 

Trust.

Case 16-34399-KRH Doc 23 Filed 09/08/17 Entered 09/08/17 15:55:15 Desc Main

 Document Page 3 of 10
Yvonne Cochran, VSBN 26015

COCHRAN LAW FIRM, P.C.

4509 West Broad Street

Richmond, VA 23230 

(804) 358-2222

Counsel for Debtor

WHEREFORE, the Debtor prays that this Court:

1. Enter an order approving the terms of the Loan Modification Agreement and acknowledging 

that the Parties have modified the Note and Deed of Trust in Accordance with the terms of 

the Loan Modification Agreement; and

2. That the 14-day stay described by Bankruptcy Rule 4001 (a) (3) be waived.

3. Grant such other and further relief as this Court deems proper.

Respectfully Submitted,

Barbara A. Sledge 

By: /s/ Yvonne Cochran

Yvonne Cochran, VSB #26015

COCHRAN LAW FIRM, P.C.

4509 West Broad Street 

Richmond, VA 23230

(804) 358-2222

Counsel for Debtor

CERTIFICATE OF SERVICE

I hereby certify that on this 8th day of September, 2017, the following person(s) were 

served electronically via the CM/ECF system, or were mailed a copy of the foregoing Motion by 

first class mail, postage prepaid:

Suzanne E. Wade, Trustee

PO Box 1780

Richmond, VA 23218-1780

Carrington Mortgage Services, LLC

1600 South Douglass Road

Anaheim, CA 92806

Cassandra J. Richey, Attorney for Carrington Mortgage Services, LLC.

Prober & Raphael, A Law Corporation

20750 Ventura Blvd. Suite 100

Woodland Hills, CA 91364

Case 16-34399-KRH Doc 23 Filed 09/08/17 Entered 09/08/17 15:55:15 Desc Main

 Document Page 4 of 10
Yvonne Cochran, VSBN 26015

COCHRAN LAW FIRM, P.C.

4509 West Broad Street

Richmond, VA 23230 

(804) 358-2222

Counsel for Debtor

Barbara A. Sledge 

3531 Dorset Road

Richmond, VA 23234

All Creditors (List Attached)

Case 16-34399-KRH Doc 23 Filed 09/08/17 Entered 09/08/17 15:55:15 Desc Main

 Document Page 5 of 10
Yvonne Cochran, VSBN 26015

COCHRAN LAW FIRM, P.C.

4509 West Broad Street

Richmond, VA 23230 

(804) 358-2222

Counsel for Debtor

UNITED STATES BANKRUPTCY COURT

EASTERN DISTRICT OF VIRGINIA

Richmond Division

In re: Barbara A. Sledge, )

)

)

)

 Case No. 16-34399-KRH

Debtor. Chapter 13

NOTICE OF MOTION AND HEARING

PLEASE TAKE NOTICE: Barbara A. Sledge (the “Debtor”), by counsel, has filed a 

Motion with the Court to Approve Loan Modification Agreement and being more particularly 

described in the Motion attached hereto.

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 you or your attorney must, on or before (21) 

days, after service of this Motion:

 X File with the court, at the address shown below, a written request for a hearing. If 

you mail your request 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

701 East Broad Street, Room 4000

Richmond, Virginia 23219

You must also mail a copy of any such response to:

Yvonne Cochran, Esquire

COCHRAN LAW FIRM, P.C.

4509 West Broad Street

Suzanne E. Wade, Trustee

P.O. Box 1780

Richmond, VA 23218-1780

Richmond, VA 23230

Attend the hearing on the motion scheduled to be held on October 25th 2017 at 12:00 

p.m. at the United States Bankruptcy Court, Eastern District of Virginia, Richmond, Division, 

701 East Broad Street, Room 5000, Richmond, Virginia 23219. 

Case 16-34399-KRH Doc 23 Filed 09/08/17 Entered 09/08/17 15:55:15 Desc Main

 Document Page 6 of 10
Yvonne Cochran, VSBN 26015

COCHRAN LAW FIRM, P.C.

4509 West Broad Street

Richmond, VA 23230 

(804) 358-2222

Counsel for Debtor

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 and may enter an Order granting the relief.

Barbara A. Sledge

By: /s/ Yvonne Cochran

Yvonne Cochran, VSB #26015

COCHRAN LAW FIRM, P.C.

4509 West Broad Street 

Richmond, VA 23230

(804) 358-2222

Counsel for Debtor

CERTIFICATE OF SERVICE

I hereby certify that on this 8th day of September, 2017, the following person(s) were 

served electronically via the CM/ECF system, or were mailed a copy of the foregoing Motion by 

first class mail, postage prepaid:

Suzanne E. Wade, Trustee

PO Box 1780

Richmond, VA 23218-1780

Carrington Mortgage Services, LLC 

1600 South Douglass Road

Anaheim, CA 92806

Cassandra J. Richey, Attorney for Carrington Mortgage Services, LLC.

Prober & Raphael, A Law Corporation

20750 Ventura Blvd. Suite 100

Woodland Hills, CA 91364

Barbara A. Sledge

3531 Dorset Road

Richmond, VA 23234

All Creditors (List Attached)

/s/ Yvonne Cochran

Yvonne Cochran, VSB #26015

Case 16-34399-KRH Doc 23 Filed 09/08/17 Entered 09/08/17 15:55:15 Desc Main

 Document Page 7 of 10
Yvonne Cochran, VSBN 26015

COCHRAN LAW FIRM, P.C.

4509 West Broad Street

Richmond, VA 23230 

(804) 358-2222

Counsel for Debtor

List of Creditors:

Carrington Mortgage Service

Attn: Bankruptcy Dept.

PO Box 3489

Anaheim, CA 92803

Chippenham & Johnston-Wil

Attn: Bankruptcy Notificatio

PO Box 13620

Richmond, VA 23225-8620

City of Richmond

Division of Collections

P.O. Box 26505

Richmond, VA 23261-6624

Credit Acceptance

25505 West 12 Mile Rd

Suite 3000

Southfield, MI 48034

Credit Acceptance

Po Box 513

Southfield, MI 48037

Credit First/CFNA

Bk13 Credit Operations

Po Box 818011

Cleveland, OH 44181

Credit First/CFNA

6275 Eastland Rd

Brookpark, OH 44142

Firestone/Credit First

Attn: Bankruptcy Dept.

P.O. Box 81344

Cleveland, OH 44188

Langley Fed Credit Uni

1055 W Mercury Blvd

Hampton, VA 23666

Mccarthy Burgess & Wol

26000 Cannon Rd

Cleveland, OH 44146

Mechanicsville Med Center

Bankruptcy Dept.

7571 Cold Harbor Road

Mechanicsville, VA 23111

NPAS, Inc.

One Park Plaza

Nashville, TN 37203

NTelos Communications, Inc.

1154 Shenadoah Village Drive

P.O. Box 1990

Waynesboro, VA 22980

Onemain Financial/Citifinanc

6801 Colwell Blvd

Ntsb-2320

Irving, TX 75039

Onemain Financial/Citifinancial

Po Box 499

Hanover, MD 21076

Patient First

Attn: Billing/Bankruptcy Dept.

P.O. Box 758941

Baltimore, MD 21275-8941

Receivables Management Sy

Attn: Bankruptcy Dept

7206 Hull Street Road

North Chesterfield, VA 2323

Thomas E. Clements, Trustee

c/oShelton, Harrison, & Pinson

701 Highlander Blvd., Ste 270

Arlington, TX 76015

Wells Fargo Dealer Services

Po Box 3569

Rancho Cucamonga, CA 91729

Wells Fargo Dealer Services

Po Box 1697

Winterville, NC 28590

Case 16-34399-KRH Doc 23 Filed 09/08/17 Entered 09/08/17 15:55:15 Desc Main

 Document Page 8 of 10
Yvonne Cochran, VSBN 26015

COCHRAN LAW FIRM, P.C.

4509 West Broad Street

Richmond, VA 23230 

(804) 358-2222

Counsel for Debtor

LIST OF EXHIBITS

Exhibit “1” Recorded First Deed of Trust and Note

Exhibit “2” First Mortgage Proof of Claim

Exhibit “3” Loan Modification Agreement

Case 16-34399-KRH Doc 23 Filed 09/08/17 Entered 09/08/17 15:55:15 Desc Main

 Document Page 9 of 10
Yvonne Cochran, VSBN 26015

COCHRAN LAW FIRM, P.C.

4509 West Broad Street

Richmond, VA 23230 

(804) 358-2222

Counsel for Debtor

UNITED STATES BANKRUPTCY COURT

EASTERN DISTRICT OF VIRGINIA

Richmond Division

In re: Barbara A. Sledge, )

)

)

)

Case No. 16-34399-KRH

Debtor. Chapter 13

SUMMARY OF THE PROPOSED LOAN MODIFICATION

Original Loan Modified Loan (60 months)

Principal Amount $180,373.29 $192,693.34

Interest Rate 10.308% 4.75 (for 245 months)

Term of Maturity Date 12/1/2037 (Prior Modified 

Date)

12/2/2037 (Extended by One 

Day)

Monthly Payment $1,691.54(P&I) $1,230.20(P&I) (for 245 

months)

1. N/A The modified loan includes future payment changes or balloon payments. The 

terms of any such future payment changes or balloon payments are: shall accrue with no 

interest and be deferred. The deferred amount will be due in full at the earlier of 

payment in full of Note, or the maturity date. 

2. N/A The modification results in a higher monthly payment. The source(s) of the funds 

used to make that payment is/are:

3. X The modification results in a lower monthly payment. Choose one of the 

following:

a. ___The amount of future plan payments will be increased.

b. X The amount of future plan payments will not be increased.

.

Case 16-34399-KRH Doc 23 Filed 09/08/17 Entered 09/08/17 15:55:15 Desc Main

 Document Page 10 of 10