UNITED STATES BANKRUPTCY COURT

EASTERN DISTRICT OF VIRGINIA

RICHMOND DIVISION

In re: Vicki Lynn Hayford, Debtor ) Case No. 16-31292-KRH

) Chapter 13

NOTICE OF HEARING AND OBJECTION TO CONFIRMATION

COMES NOW the Chapter 13 Trustee, Suzanne E. Wade, and moves this Court to deny 

confirmation of the plan dated March 16, 2016, for the cause as follows:

1. The Debtor filed this Chapter 13 Petition, now pending in the United States Bankruptcy Court, 

Eastern District of Virginia, Richmond Division, on March 16, 2016 under 11 U.S.C. Chapter 13.

2. This Objection is filed pursuant to 11 U.S.C. § 1325.

3. The Trustee would request the Debtor provide a current market analysis for the Debtor’s real 

property located at 8013 Sycamore Lane, Henrico, VA 23228.

WHEREFORE, for the reasons stated herein, the Chapter 13 Trustee respectfully moves the Court to deny 

confirmation of the Debtor’s proposed Chapter 13 Plan, and for such further and other relief as the Court 

deems necessary.

Notice is hereby given, pursuant to Local Rule 3015(E)(2), that a hearing on this 

motion will be held at United States Bankruptcy Court, 701 East Broad Street, Room 

5000, Richmond, Virginia, 23219, on June 8, 2016 at 11:10 A.M.

Date: May 19, 2016

 Chapter 13 Trustee 

/s/ Suzanne E. Wade___ 

Suzanne E. Wade, Chapter 13 Trustee

Virginia State Bar Number 31868

1313 East Main Street, Suite A

Post Office Box 1780

Richmond, Virginia 23218-1780

(804) 775-0979

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CERTIFICATE OF SERVICE

I hereby certify a true copy of the foregoing NOTICE OF HEARING AND OBJECTION TO 

CONFIRMATION was served by first-class mail, postage prepaid, this 19th day of May, 2016, upon the 

Debtor, Vicki Lynn Hayford, at 8013 Sycamore Lane, Henrico, VA 23228. Debtor’s counsel, Richard 

James Oulton, Esquire, was served by electronic notification to 2debtlawgroup@gmail.com.

 Chapter 13 Trustee 

/s/ Suzanne E. Wade___

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UNITED STATES BANKRUPTCY COURT

EASTERN DISTRICT OF VIRGINIA

RICHMOND DIVISION

In re: Vicki Lynn Hayford, Debtor ) Case No. 16-31292-KRH

) Chapter 13

8013 Sycamore Lane )

Henrico, VA 23228 )

)

 XXX-XX-0377 )

NOTICE OF OBJECTION TO CONFIRMATION

Suzanne E. Wade, Chapter 13 Trustee, has filed papers with the Court objecting to the 

confirmation of your Chapter 13 Plan dated March 16, 2016.

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 Objection, or if you want the Court to 

consider your views on the Objection, then on or before three (3) days before the date of the hearing, you 

or your attorney must:

File with the Court, at the address shown below, a written response pursuant to Local 

Bankruptcy Rule 9013-1(H). If you mail your response to the Court for filing, you must 

mail it early enough that the Court will receive it on or before the date stated above.

Clerk of Court

United States Bankruptcy Court

701 East Broad Street, Suite 4000

Richmond, Virginia 23219

You must also mail a copy to:

Suzanne E. Wade, Chapter 13 Trustee

Post Office Box 1780

Richmond, Virginia 23218-1780

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

relief sought in the Objection, and may enter an order granting that relief.

Date: May 19, 2016

 Chapter 13 Trustee 

/s/ Suzanne E. Wade___

Suzanne E. Wade, Chapter 13 Trustee

Virginia State Bar Number 31868

1313 East Main Street, Suite A

Post Office Box 1780

Richmond, Virginia 23218-1780

(804) 775-0979

Case 16-31292-KRH Doc 11 Filed 05/19/16 Entered 05/19/16 10:20:23 Desc Main

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CERTIFICATE OF SERVICE

I hereby certify a true copy of the foregoing NOTICE OF OBJECTION TO CONFIRMATION

was served by first-class mail, postage prepaid this 19th day of May, 2016, upon the Debtor, Vicki Lynn 

Hayford, at 8013 Sycamore Lane, Henrico, VA 23228. Debtor’s counsel, Richard James Oulton, 

Esquire, was served by electronic notification to 2debtlawgroup@gmail.com.

 Chapter 13 Trustee 

/s/ Suzanne E. Wade___

Case 16-31292-KRH Doc 11 Filed 05/19/16 Entered 05/19/16 10:20:23 Desc Main

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