1

Brad M. Barna, Esq. VSB No. 88993

Chadwick, Washington, Moriarty, Elmore & Bunn, P.C.

Woodland Park Homeowners Association

3201 Jermantown Rd., Suite 600

Fairfax, VA 22030

Ph. (703) 352-1900 Fax. (703) 352-5293

bbarna@chadwickwashington.com

UNITED STATES BANKRUPTCY COURT

EASTERN DISTRICT OF VIRGINIA

Alexandria Division

In re: )

) Case No. 17-13654-BFK

BAHRAM AFSHAR ) Chapter 13

)

)

Debtor. )

OBJECTION TO CONFIRMATION OF PLAN, 

NOTICE OF OBJECTION TO CONFIRMATION OF PLAN, AND

NOTICE OF SCHEDULED HEARING ON THIS MOTION

Woodland Park Homeowners Association (the “Association”), a secured creditor in part, by 

counsel, has filed this objection to confirmation of the Debtor’s Chapter 13 Plan dated 

November 28, 2017, as a result of Debtors’ failure in the proposed Plan to recognize the prepetition debt owed to the Association, and states as follows:

1 The Debtors filed a petition in this court under Chapter 13 of Title 11, United States Code 

(the Bankruptcy Code) on October 28, 2017.

2 The Association’s Proof of Claim was timely filed on January 2, 2018 (Claim #3), showing 

a total claim amount of $18,212.06. Of this, $14,408.89 is secured by two perfected 

statutory assessment liens and three judgment liens. The remaining claim of $3,803.17 is 

unsecured.

3 The debtor’s Chapter 13 Plan fails to recognize any arrearage owed to the Association. 

WHEREFORE, the Association prays that its Objection be sustained, and that 

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

this Court deems proper and just.

Case 17-13654-BFK Doc 27 Filed 01/03/18 Entered 01/03/18 13:01:15 Desc Main

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2

Brad M. Barna, Esq. VSB No. 88993

Chadwick, Washington, Moriarty, Elmore & Bunn, P.C.

Woodland Park Homeowners Association

3201 Jermantown Rd., Suite 600

Fairfax, VA 22030

Ph. (703) 352-1900 Fax. (703) 352-5293

bbarna@chadwickwashington.com

Respectfully submitted,

Woodland Park Homeowners Association

By Counsel

 /s/ Brad M. Barna 

Brad M. Barna, VSB No. 88993

Chadwick, Washington, Moriarty,

 Elmore, & Bunn, P.C.

3201 Jermantown Road, Suite 600

Fairfax, VA 222030

Ph. (703) 352-1900

Email: bbarna@chadwickwashington.com

CERTIFICATE OF SERVICE

I hereby certify that a copy of the foregoing Notice and Objection to Confirmation of 

Chapter 13 Plan and Notice of Scheduled Hearing were sent this 3rd day of January 2018, via 

electronic notice to the following:

Thomas P. Gorman, Chapter 13 Trustee Michael J. O. Sandler, Esquire

300 N. Washington Street, Ste. 400 Fisher-Sandler, LLC

Alexandria, VA 22314 12801 Darby Brooke Court, Suite 201

Woodbridge, VA 22192

Attorney for Debtor

 /s/ Brad M. Barna

Brad M. Barna

Case 17-13654-BFK Doc 27 Filed 01/03/18 Entered 01/03/18 13:01:15 Desc Main

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3

Brad M. Barna, Esq. VSB No. 88993

Chadwick, Washington, Moriarty, Elmore & Bunn, P.C.

Woodland Park Homeowners Association

3201 Jermantown Rd., Suite 600

Fairfax, VA 22030

Ph. (703) 352-1900 Fax. (703) 352-5293

bbarna@chadwickwashington.com

NOTICE OF OBJECTION TO PLAN, NOTICE OF SCHEDULED HEARING

Creditor, Woodland Park Homeowners Association has filed this Objection to Confirmation 

of the proposed Chapter 13 Plan filed in case 17-13459-BFK on November 28, 2017.

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 wish the court to grant the relief sought in the motion, or if you want the court 

to consider your views on the objection, then on or prior to the hearing date, you or your attorney 

must:

File with the court, at the address shown below, a written response with supporting 

memorandum as required by Local Bankruptcy Rule 9013-1 (H). Unless a written 

response and supporting memorandum are filed and served by the date specified, the 

Court may deem any opposition waived, treat the motion as conceded, and issue an 

order granting the requested relief without further notice or hearing. If you mail your 

response to the court for filing, you must mail it early enough so the court will receive it 

on or before the date stated above. You must also mail a copy to the persons listed 

below. 

Attend the hearing scheduled to be held on January 11, 2018 at 1:30 p.m. in Courtroom 

#1, United States Bankruptcy Court, 200 South Washington Street, Alexandria, Virginia 

22314. If no timely response has been filed opposing the relief requested, the court may 

grant the relief without holding a hearing.

A copy of any written response must be mailed to the following persons:

Woodland Park Homeowners Association

c/o Chadwick, Washington, Moriarty, Elmore & Bunn, P. C.

3201 Jermantown Road, Suite 600

Fairfax, VA 22030

Clerk of the Court

United States Bankruptcy Court

200 South Washington Street

Alexandria, VA 22314

 Thomas P. Gorman, Chapter 13 Trustee

 300 N. Washington Street, Ste. 400

 Alexandria, VA 22314

Case 17-13654-BFK Doc 27 Filed 01/03/18 Entered 01/03/18 13:01:15 Desc Main

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4

Brad M. Barna, Esq. VSB No. 88993

Chadwick, Washington, Moriarty, Elmore & Bunn, P.C.

Woodland Park Homeowners Association

3201 Jermantown Rd., Suite 600

Fairfax, VA 22030

Ph. (703) 352-1900 Fax. (703) 352-5293

bbarna@chadwickwashington.com

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 or objection and may enter an order granting that relief.

CERTIFICATE OF SERVICE

I hereby certify that a copy of the foregoing Notice and Objection to Confirmation of 

Chapter 13 Plan and Notice of Scheduled Hearing were sent this 3rd day of January 2018, via 

electronic notice to the following:

Thomas P. Gorman, Chapter 13 Trustee Michael J. O. Sandler, Esquire

300 N. Washington Street, Ste. 400 Fisher-Sandler, LLC

Alexandria, VA 22314 12801 Darby Brooke Court, Suite 201

Woodbridge, VA 22192

Attorney for Debtor

 /s/ Brad Barna 

Brad Barna

Case 17-13654-BFK Doc 27 Filed 01/03/18 Entered 01/03/18 13:01:15 Desc Main

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