ALEXANDER M. LAUGHLIN (VSB No. 25237) 

Counsel for Trustee 

ODIN, FELDMAN & PITTLEMAN, P.C. 

1775 Wiehle Avenue, Suite 400 

Reston, Virginia 20190 

Laughlin: 703-218-2134 

Fax: 703-218-2160 

Email: Alex.Laughlin@ofplaw.com 

UNITED STATES BANKRUPTCY COURT 

FOR THE EASTERN DISTRICT OF VIRGINIA 

Alexandria Division 

In re: * 

* 

MICHAEL BOWAN SIVY, * Case No. 18-12656-BFK 

 * Chapter 7

* 

Debtor. * _____________________________________________________________________ 

U.S. BANK NATIONAL ASSOCIATION, AS * 

TRUSTEE FOR STRUCTURED * 

ADJUSTABLE RATE MORTGAGE LOAN * 

TRUST, MORTGAGE PASS-THROUGH * 

CERTIFICATES, SERIES 2006-4 * 

* 

Movant, * 

* 

v. * 

* 

MICHAEL BOWAN SIVY * 

 * 

and * 

 * 

DONALD F. KING, TRUSTEE * 

* 

Respondents. * 

ANSWER AND OPPOSITION TO MOTION FOR RELIEF FROM AUTOMATIC STAY 

DONALD F. KING, TRUSTEE (“Trustee”), by counsel, files his Answer and 

Opposition to the Motion for Relief From the Automatic Stay (“Motion”) filed by U.S. Bank 

National Association, as Trustee For Structured Adjustable Rate Mortgage Loan Trust, Mortgage 

Pass-Through Certificates, Series 2006-4 (“Movant”) in the above referenced case for the 

property located at 43884 River Point Drive, Leesburg, VA 20176 (“Property”), and states as 

follows: 

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1. The Trustee admits the allegations contained in Paragraphs 1-2. 

2. The Trustee, lacking sufficient knowledge of the allegations contained in 

Paragraphs 3-9 of the Motion, neither admits nor denies such allegations and requires proof 

thereof. 

3. The Trustee admits the allegations contained in Paragraph 10 that the Debtors 

scheduled the value of the Property at $850,000.00. 

4. The Trustee lacks sufficient knowledge of the allegations contained in Paragraph 

11 of the Motion and neither admits or denies such allegations and requires proof thereof. 

5. The Trustee denies the allegations in Paragraphs 12 and 13 of the Motion. 

AFFIRMATIVE DEFENSE

Movant alleges that the unpaid principal amount due under its Note with the Debtor is 

approximately $468,201.99. The Debtor scheduled the value of the Property at $850,000.00. 

The Trustee is evaluating the extent of the equity in the property. Assuming, without admitting, 

that Movant’s allegations in the Motion are correct, there is an equity cushion protecting 

Movant’s alleged interest in the Property. 

WHEREFORE, Donald F. King, Trustee, by counsel, requests that this Court enter an 

order denying Movant’s Motion for Relief from the Automatic Stay. 

DONALD F. KING, TRUSTEE 

By Counsel 

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By: /s/ Alexander M. Laughlin 

ALEXANDER M. LAUGHLIN, ESQUIRE (VSB No. 25237) 

 Counsel for Trustee 

 ODIN FELDMAN & PITTLEMAN PC 

 1775 Wiehle Avenue, Suite 400 

 Reston, Virginia 20190 

 Phone: 703-218-2134 

 Fax: 703-218-2160 

Alex.Laughlin@ofplaw.com 

CERTIFICATE OF SERVICE 

 I HEREBY CERTIFY that a true and accurate copy of the foregoing Opposition was sent 

on the 5th day of November, 2018 via Notice of Electronic Filing to all registered users in this 

case pursuant to this Court’s CM/ECF Policy, including Counsel for the Movant, The U.S. Bank 

National Association, As Trustee For Structured Adjustable Rate Mortgage Loan Trust, 

Mortgage Pass-Through Certificates, Series 2006-4, and counsel for the Debtor. 

Heather D. McGivern 

Post Office Box 2548 

Leesburg, VA 20177 

Robert Sergio Brandt 

The Law Offices of Robert S. Brandt 

1513 King Street 

Alexandria, VA 22314 

Michael Bowan Sivy 

43884 River Point Drive 

Leesburg, VA 20176 

/s/ Alexander M. Laughlin 

Alexander M. Laughlin 

#4089767v1 31070/00001 

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