Susan H. Call, Esquire

Staff Counsel for

Carl M. Bates

P.O. Box 1819

Richmond, VA 23218-1819

(804) 237-6800

VSBN 34367

UNITED STATES BANKRUPTCY COURT

EASTERN DISTRICT OF VIRGINIA

RICHMOND DIVISION

In re: Debera Ann Walker ) Case No: 16-30408

) Chapter 13

TRUSTEE’S OBJECTION TO EXEMPTIONS

AND NOTICE OF OBJECTION

COMES NOW, Susan H. Call, Counsel for Carl M. Bates the Chapter 13 

Trustee, pursuant to Federal Rule of Bankruptcy procedure 4003(b), and as for her 

Objection to Exemptions taken by the Debtors in property of this estate, states as follows:

1. On February 2, 2016, Debera Ann Walker (“Debtor”) filed a voluntary petition 

under Chapter 13 of the United States Bankruptcy Code.

2. Carl M. Bates is appointed Chapter 13 Trustee in this case and continues to 

serve as Trustee.

3. The first meeting of creditors was held on March 3, 2016 and was concluded.

4. Debtor, in Schedule C, of her Bankruptcy Petition (“Schedule C”) has indicated 

they she is claiming equity in “Stocks for corporate employer” (hereinafter known as 

“stocks”) in the amount of $2,027.00 exempt under Va. Code Ann. § 34-34.

5. Upon evidence, and belief, the claim for the “stocks” is not one of such a nature 

that is exempt under Va. Code Ann. § 34-34. 

6. Susan H. Call, Counsel for the Chapter 13 Trustee, avers that the exemption 

claims of the Debtor for the “stocks” is not proper under the code section claimed, and 

should be disallowed. 

Case 16-30408-KRH Doc 12 Filed 04/01/16 Entered 04/01/16 09:21:42 Desc Main

 Document Page 1 of 4
Susan H. Call, Esquire

Staff Counsel for

Carl M. Bates

P.O. Box 1819

Richmond, VA 23218-1819

(804) 237-6800

VSBN 34367

WHEREFORE, the Chapter 13 Trustee, by Counsel, prays for entry of an Order 

by this Court: determining that the exemption taken by the Debtor, with respect to the

aforementioned “stock” claimed exempt on Schedule C, is improper and disallowed in 

full under Va. Code Ann. § 34-34, and granting such other and further relief as is just.

/s/Susan H. Call

Susan H. Call, 

Counsel for

Carl M. Bates

Chapter 13 Trustee

Certificate of Service

I hereby certify that on April 1, 2016, I have mailed or hand-delivered a true copy 

of the foregoing Objection to Exemption to the debtor(s), Debera Ann Walker, 1653 W. 

Clara Dr., Petersburg, VA 23803 and electronically sent to debtor’s attorney, Richard 

James Oulton, Esquire, 2debtlawgroup@gmail.com.

/s/Susan H. Call

Susan H. Call, Counsel for

Carl M. Bates

Chapter 13 Trustee

Case 16-30408-KRH Doc 12 Filed 04/01/16 Entered 04/01/16 09:21:42 Desc Main

 Document Page 2 of 4
Susan H. Call, Esquire

Staff Counsel for

Carl M. Bates

P.O. Box 1819

Richmond, VA 23218-1819

(804) 237-6800

VSBN 34367

UNITED STATES BANKRUPTCY COURT

EASTERN DISTRICT OF VIRGINIA

RICHMOND DIVISION

In re: Debera Ann Walker ) Case No: 16-30408

) Chapter 13

Debtor Address 1653 W. Clara Drive

Petersburg, VA 23803

Last four digits of Social Security No(s).: 3200

NOTICE OF OBJECTION TO EXEMPTIONS

Carl M. Bates, by Counsel, the Chapter 13 Trustee in Bankruptcy (the “Trustee”) has 

filed a “TRUSTEE’S OBJECTION TO EXEMPTIONS” (the “Objection”) with the 

Court, seeking to disallow exemptions in property claimed by debtor, Debera Ann 

Walker (the “Debtor”).

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 sustain the Objection, or if you want the 

court to consider your views on the Objection, you or your attorney must: 

File with the court, on or before twenty-one days from the service date of 

this Notice, at the address shown below, a written response to the 

Objection requesting a Hearing.

Clerk of Court

United States Bankruptcy Court

701 East Broad Street

Richmond, VA 23219

You must also mail a copy to:

Susan H. Call

Counsel for Carl M. Bates, Chapter 13 Trustee

P. O. Box 1819

Richmond, VA 23218

Case 16-30408-KRH Doc 12 Filed 04/01/16 Entered 04/01/16 09:21:42 Desc Main

 Document Page 3 of 4
Susan H. Call, Esquire

Staff Counsel for

Carl M. Bates

P.O. Box 1819

Richmond, VA 23218-1819

(804) 237-6800

VSBN 34367

OR Attend a hearing to be scheduled at April 27, 2016, 2016 at 11:10 am at The United States 

Bankruptcy Court for the Eastern District of Virginia, 701 East Broad Street, Room 5000, 

Richmond, Virginia 23219. If no timely response has been filed opposing the relief requested, 

the court may grant the relief without holding a hearing.

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

oppose the request and permit the sale to proceed without further action of the Court.

Date: April 1, 2016 /s/Susan H. Call

 Susan H. Call, Counsel for

Carl M. Bates

Chapter 13 Trustee

Certificate of Service

I hereby certify that on April 1, 2016, I have mailed or hand-delivered a true copy 

of the foregoing Notice of Objection to Exemption to the debtor(s) Debera Ann Walker, 

1653 W. Clara Dr., Petersburg, VA 23803 and electronically sent to debtor’s attorney, 

Richard James Oulton, Esquire, 2debtlawgroup@gmail.com.

.

/s/Susan H. Call

Susan H. Call, Counsel for

Carl M. Bates

Chapter 13 Trustee

Case 16-30408-KRH Doc 12 Filed 04/01/16 Entered 04/01/16 09:21:42 Desc Main

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