UNITED STATES BANKRUPTCY COURT

 EASTERN DISTRICT OF VIRGINIA 

ALEXANDRIA DIVISION

In re: :

 Mary Margaret Charlotte Soubra : Case No. 17-10307-BFK

 : Chapter 13

 Debtor 

MOTION TO APPROVE LOAN MODIFICATION AND MEMORANDUM OF 

 POINTS AND AUTHORITIES

COMES NOW, Debtor, by her undersigned counsel and to this Honorable Court,

respectfully represents as follows:

1. Debtor, Mary Margaret Charlotte Soubra is indebted to SunWest Mortgage Company,

INC., in the approximate amount of $244,007.87, including all arrears, secured by her residence

at 4601 Eastlawn Ave., Woodbridge VA 22193

2. SunWest Mortgage Company, INC. has agreed to modify the Debtor’s mortgage loan.

The proposed unexecuted, loan modification terms are attached as Exhibit 1. The new principal

balance will be $244,007.87.

3. Pursuant to paragraph 10 of the confirmed chapter 13 plan, Court permission is

required to approve this modification.

4. As a result of the loan modification agreement, Debtor’s monthly mortgage payment

will be $1,494.62 principal, interest and escrow per month. Interest rate will be at 3.25% fixed

for 30 years. The original interest rate was 3.75% per annum. The pre-modification monthly

mortgage installment was approximately $1,668.00 per month. The loan modification will reduce

the length of the plan and permit the Debtor to leave chapter 13 protection early. Debtor will

amend her plan to reflect the overall increase of the amounts payable in the plan, by $173.38.

5. The new modified principal balance of $244,007.87 will include all amounts, including

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arrearages.

6. This modification is in the best interest of the Debtor and the estate because the new

payment amount is lower than the current amount and all mortgage arrears are taken from the

chapter 13 plan and rolled into the loan modification.

7. If the modification is approved by the Court, Debtor will file an amended chapter 13

plan increasing her plan payment by the amount of the mortgage payment reduction under the

new payment.

WHEREFORE, Debtor asks that this Honorable Court approve the subject loan

modification. 

Date: May 12, 2021 Mary Margaret Charlotte Soubra, Debtor

By Counsel 

/s/John D. Sawyer 

John D. Sawyer, Esq.

Sawyer & Azarcon, P.C.

10605 B-2 Judicial Drive 

Fairfax, VA 22030

(703) 893-0760

Bar No. 28170

Counsel for Debtors 

CERTIFICATE OF SERVICE 

I hereby certify that on this 12th day of May, 2021 a copy of the foregoing instrument was

mailed postage prepaid to the debtor, Trustee and all creditors and parties in interest. 

/s/ John D. Sawyer

John D. Sawyer, Esq.

[Soubra.LM.Appr.MTN]

PARTIES TO RECEIVE COPIES:

Mary M.C. Soubra

4601 Eastlawn Ave.,

Woodbridge, VA 22193

Ally Financial

Po Box 380902

Bloomington, MN 55438

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Barclays Bank Delaware

100 S West St

Wilmington, DE 19801

Consol Plus

1875 South Grant Street

San Mateo, CA 94402

Genesis Bankcard Srvs

15220 Nw Greenbrier Pkwy

Suite 200

Beaverton, OR 97006

Inova Lab

2832 Juniper Street

Fairfax, VA 22031

Inova Physical Therapy

14605 Potomac Branch Drive

Woodbridge, VA 22191

Internal Revenue Service

400 N 8th St, Box 76

Stop Room 898

Richmond, VA 23219

Internal Revenue Service

PO Box 7346

Philadelphia, PA 19101-7346

Lending Club Corp

71 Stevenson St

Suite 300

San Francisco, CA 94105

Net Credit Financial

Po Box 645295

Cincinnati, OH 45264

Onemain

Po Box 1010

Evansville, IN 47706

PayPal Credit

PO Box 5018

Timonium, MD 21095

Purchasing Power

1349 W Peachtree Street,

Suite 1100

Atlanta, GA 30309

Sun West Mortgage Co I

18000 Studebaker Road, #200

Cerritos, CA 90703

Virginia Dept of Taxation

PO Box 1880

Richmond, VA 23218-1880

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