James E. Kane (VSB #30081) 

KANE & PAPA, P.C. 

1313 East Cary Street 

Richmond, VA 23219 

(804) 225-9500 (phone) 

(804) 225-9598 (fax) 

Counsel for Debtors 

IN THE UNITED STATES BANKRUPTCY COURT 

FOR THE EASTERN DISTRICT OF VIRGINIA 

Richmond Division 

 

IN RE: ) 

 ) 

JOHN WILLIAM COPPEDGE ) Case No. 18-31387-KRH 

JANICE SHANNON COPPEDGE ) Chapter 13 

 ) 

 Debtors ) 

MOTION TO SELL REAL ESTATE 

 COME NOW, the Debtors, by counsel, and as and for Debtors’ Motion to Sell Real 

Estate, state as follows: 

 1. The Debtors filed this case under Chapter 13 of the U.S. Bankruptcy Code on 

March 18, 2018. 

 2. Select Portfolio Servicing, Inc. is a secured creditor which holds a mortgage on 

the property known as 293 Cedar Fork Road, Henrico, VA 23223, more particularly known as: 

ALL THAT CERTAIN OR PARCEL OF LAND WITH THE IMPROVEMENTS 

THEREON AND APPURTENANCES THERETO BELONGING, LYING, 

BEING AND SITUATE IN FAIRFIELD DISTRICT, HENRICO COUNTY, 

VIRGINGA, DESIGNATED AS LOT 5, BLOCK A, SECTION A, CEDAR 

FORKS ESTATES, AS MORE PARTICULARLY SHOWN ON PLAT OF 

SUBDIVISION ENTITLED “CEDAR FORKS ESTATES, SECTION A,” 

MADE BY BODIE, TAYLOR, PURYEAR, INC., ENGINEERS AND 

SURVEYORS, DATED JANUARY 27, 1994, RECORDED JANUARY 31, 

1994, IN THE CLERK’S OFFICE, CIRCUIT COURT, HENRICO COUNTY, 

VIRGINIA, IN PLAT BOOK 99, PAGE 10, REFERENCE TO WHICH IS 

HEREBY MADE FOR A MORE PARTICULAR DESCRIPTION OF SAID 

REAL ESTATE.. 

 (the “Property”). 

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3. The approximate payoff balance on the note secured by said mortgage is 

$132,238.47. The tax assessed value of the Property is $169,600.00. 

 4. Debtors entered into a contract (“Contract”) for the sale of the Property for 

$235,000.00, which, upon closing of the same, will result in Select Portfolio Servicing, Inc 

releasing its deed of trust against the Property. A copy of said contract is attached hereto 

collectively as Exhibit “A” and incorporated herein by this reference. 

5. The amount of the proceeds to be applied to the Debtors’ obligations under the 

confirmed plan in this case is $27,120.00, which will result in full payment of the Chapter 13 

Plan. 

6. On December 30, 2020, or as soon thereafter as may be practicable, Debtors 

intend to sell their interest in the Property in accordance with the terms of the Contract. 

WHEREFORE, the Debtors request that the Court enter an Order authorizing the sale of 

the Property in accordance with the terms of the Contract and for such other relief as the Court 

may deem appropriate 

Dated: November 24, 2020 JOHN WILLIAM COPPEDGE 

 JANICE SHANNON COPPEDGE 

 By: /s/ James E. Kane 

 Counsel 

James E. Kane (VSB #30081) 

KANE & PAPA, P.C. 

1313 East Cary Street 

Richmond, VA 23219 

(804) 225-9500 (phone) 

(804) 225-9598 (fax) 

Counsel for Debtors 

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CERTIFICATE OF SERVICE 

I hereby certify that on November 24, 2020, I will electronically file the foregoing with 

the Clerk of Court using the CM/ECF system, which will then send a notification of such filing 

(NEF) to all parties registered to receive notice thereof, and I mailed a true and exact copy to the 

parties on the list attached hereto. 

/s/ James E. Kane 

Counsel for Debtors 

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IN THE UNITED STATES BANKRUPTCY COURT 

FOR THE EASTERN DISTRICT OF VIRGINIA 

Richmond Division 

 

IN RE: ) 

 ) 

JOHN WILLIAM COPPEDGE ) Case No. 18-31387-KRH 

JANICE SHANNON COPPEDGE ) Chapter 13 

 ) 

 Debtors ) 

NOTICE OF MOTION AND HEARING 

 The above Debtors have filed a Motion to Sell Real Estate. 

 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). 

The Debtors are requesting to their primary residence known as 293 Cedar Fork Road, 

Henrico, VA 23223 for $235,000.00. The property is currently secured by a first deed of trust 

with an approximate balance of $132,238.47 which balance is to be paid in full with the proceeds 

from the sale of the property. The amount of the proceeds to be applied to the Debtor’s 

obligations under the confirmed plan in this case is $27,120.00, which will result in full payment 

of the Chapter 13 Plan. The remaining amount of the proceeds from the sale are to be paid to the 

Debtors, approximately $58,500.00 to be used for Debtor’s moving and living expenses. 

 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: 

 File with the court, at the address shown below, a written request for a hearing [or 

written response pursuant to Local Bankruptcy Rule 9013-1(H)]. If you mail your 

request for a hearing (or 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, to: 

Clerk of Court 

United States Bankruptcy Court 

701 East Broad Street 

Richmond, VA 23219 

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You must also mail a copy to: 

James E. Kane, Esquire 

KANE & PAPA, P.C. 

1313 East Cary Street 

Richmond, Virginia 23219 

 Attend a hearing scheduled for December 16, 2020 at 12:00 p.m. at U.S. 

Bankruptcy Court, 701 East Broad Street, Room 5000, Richmond, VA 

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 relief sought in the motion or objection and may enter an order granting that 

relief. 

Dated: November 24, 2020 JOHN WILLIAM COPPEDGE 

 JANICE SHANNON COPPEDGE 

 By: /s/ James E. Kane 

 Counsel 

James E. Kane (VSB #30081) 

KANE & PAPA, P.C. 

1313 East Cary Street 

Richmond, VA 23219 

(804) 225-9500 (phone) 

(804) 225-9598 (fax) 

Counsel for Debtors 

CERTIFICATE OF SERVICE 

I hereby certify that on November 24, 2020, I will electronically file the foregoing with 

the Clerk of Court using the CM/ECF system, which will then send a notification of such filing 

(NEF) to all parties registered to receive notice thereof, and I mailed a true and exact copy to the 

parties on the list attached hereto. 

/s/ James E. Kane 

Counsel for Debtors 

Case 18-31387-KRH Doc 37 Filed 11/24/20 Entered 11/24/20 15:38:38 Desc Main

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 Label Matrix for local noticing United States Bankruptcy Court Cavalry SPV I, LLC 

 0422-3 701 East Broad Street 500 Summit Lake Drive, Ste 400 

 Case 18-31387-KRH Richmond, VA 23219-1888 Valhalla, NY 10595-2321 

 Eastern District of Virginia 

 Richmond 

 Mon Nov 23 15:35:13 EST 2020 

 Citibank / Sears Citibank/The Home Depot (p)GLASSER AND GLASSER P L C 

 Citicorp Credit Services/Attn: Centraliz Citicorp Cr Srvs/Centralized Bankruptcy P O BOX 3400 

 Po Box 790040 Po Box 790040 NORFOLK VA 23514-3400 

 Saint Louis, MO 63179-0040 St Louis, MO 63179-0040 

 

 Household Finance Corp II Internal Revenue Service Midland Funding 

 c/o Glasser & Glasser P.O. Box 7346 Attn: Bankruptcy 

 580 East Main St. Ste 600 Philadelphia, PA 19101-7346 Po Box 939069 

 Norfolk, VA 23510-2322 San Diego, CA 92193-9069 

 Midland Funding LLC (p)PORTFOLIO RECOVERY ASSOCIATES LLC Quantum3 Group LLC as agent for 

 PO Box 2011 PO BOX 41067 MOMA Funding LLC 

 Warren, MI 48090-2011 NORFOLK VA 23541-1067 PO Box 788 

 Kirkland, WA 98083-0788 

 Select Portfolio Servicing, Inc Syncb/Ashley Homestore Synchrony Bank/ JC Penneys 

 Po Box 65250 Attn: Bankruptcy Attn: Bankruptcy 

 Salt Lake City, UT 84165-0250 Po Box 965060 Po Box 965060 

 Orlando, FL 32896-5060 Orlando, FL 32896-5060 

 Synchrony Bank/Care Credit Synchrony Bank/Lowes Town Bank 

 Attn: Bankruptcy Attn: Bankruptcy 109 E. Main Street, Suite 100 

 Po Box 965060 Po Box 965060 Norfolk, VA 23510-1647 

 Orlando, FL 32896-5060 Orlando, FL 32896-5060 

 TowneBank Verizon Virginia Credit Union 

 J.Louis Roussos by American InfoSource LP as agent Po Box 90010 

 6001 Harbour View Blvd. 4515 N Santa Fe Ave Richmond, VA 23225-9010 

 Suffolk, VA 23435-2767 Oklahoma City, OK 73118-7901 

 Virginia Department of Tax James E. Kane Janice Shannon Coppedge 

 P O Box 2156 Kane & Papa, PC 293 Cedar Fork Road 

 Richmond, VA 23218-2156 1313 East Cary Street Henrico, VA 23223-2718 

 P.O. Box 508 

 Richmond, VA 23218-0508 

 

 John P. Fitzgerald, III John William Coppedge III Suzanne E. Wade 

 Office of the US Trustee - Region 4 -R 293 Cedar Fork Road 341 Dial 877-996-8484 Code 2385911 

 701 E. Broad Street, Ste. 4304 Henrico, VA 23223-2718 7202 Glen Forest Drive, Ste. 202 

 Richmond, VA 23219-1849 Richmond, VA 23226-3770 

 The preferred mailing address (p) above has been substituted for the following entity/entities as so specified 

 by said entity/entities in a Notice of Address filed pursuant to 11 U.S.C. 342(f) and Fed.R.Bank.P. 2002 (g)(4). 

Case 18-31387-KRH Doc 37 Filed 11/24/20 Entered 11/24/20 15:38:38 Desc Main

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 Glasser & Glasser Portfolio Recovery Associates, LLC 

 580 E. Main St. POB 41067 

 Suite 600 Norfolk VA 23541 

 Norfolk, VA 23510-0000 

 

 The following recipients may be/have been bypassed for notice due to an undeliverable (u) or duplicate (d) address. 

 (u)U.S. Bank National Association, as indentu (d)Select Portfolio Servicing, Inc. (d)Virginia Credit Union, Inc. 

 P.O. Box 65250 PO Box 90010 

 Salt Lake City, UT 84165-0250 Richmond, VA 23225-9010 

 (d)Virginia Credit Union,Inc. End of Label Matrix 

 PO Box 90010 Mailable recipients 26 

 Richmond, VA 23225-9010 Bypassed recipients 4 

 Total 30 

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