UNITED STATES BANKRUPTCY COURT

EASTERN DISTRICT OF VIRGINIA

RICHMOND DIVISION

IN RE:

Michelle C Taylor

Debtor(s)

BCN#: 17-34844-KLP

Chapter: 13

NOTICE OF MOTION (OR OBJECTION) 

U.S. Bank National Association, as Trustee for Credit Suisse First Boston Mortgage 

Securities Corp., Home Equity Asset Trust 2005-5, Home Equity Pass-Through Certificates, 

Series 2005-5 has filed papers with the court objecting to the confirmation of the proposed 

Chapter 13 plan.

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 November 16, 2017, you or your 

attorney must:

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

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

your request for 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.

U.S. Bankruptcy Court

701 East Broad Street,

Suite 4000

Richmond, VA 23219

You must also send a copy to:

Gregory N. Britto, Esquire

Malcolm B. Savage, III, Esquire

William M. Savage, Esquire

Mary F. Balthasar Lake, Esquire

Leonard C. Tengco, Esquire

SHAPIRO & BROWN, LLP 

501 Independence Parkway, Suite 203

Chesapeake, Virginia 23320

(703) 449-5800

 Attend a hearing to be scheduled on 12/06/2017, 09:10 AM, Judge Phillips' 

Courtroom, 701 E. Broad St., Rm. 5100, Richmond, Virginia. If no timely 

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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 1, 2017 SHAPIRO & BROWN, LLP 

Attorneys for U.S. Bank National Association, as Trustee 

for Credit Suisse First Boston Mortgage Securities Corp., 

Home Equity Asset Trust 2005-5, Home Equity PassThrough Certificates, Series 2005-5

By:/s/ Mary F. Balthasar Lake

Gregory N. Britto, Esquire

VSB #23476

Malcolm B. Savage, III, Esquire

VSB #91050

William M. Savage, Esquire

VSB #26155

Thomas J. Gartner, Esquire

VSB #79340

Mary F. Balthasar Lake, Esquire

VSB #34899

Leonard C. Tengco, Esquire

VSB #76395

SHAPIRO & BROWN, LLP 

501 Independence Parkway, Suite 203

Chesapeake, Virginia 23320

(703) 449-5800

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CERTIFICATE OF SERVICE 

I certify that I have this 1st day of November, 2017, electronically transmitted and/or 

mailed by first class mail, postage pre-paid or hand-delivered a true copy of the foregoing Notice 

of Motion (or Objection) to the following:

Pia J. North

North Law

5913 Harbour Park Drive

Midlothian, VA 23112

Suzanne E. Wade

P.O. Box 1780

Richmond, VA 23218-1780

Michelle C Taylor

5701 BARNWOOD DRIVE

Richmond, VA 23234

Mary F. Balthasar Lake

Gregory N. Britto, Esquire

Malcolm B. Savage, III, Esquire

William M. Savage, Esquire

Mary F. Balthasar Lake, Esquire

Leonard C. Tengco, Esquire

Gregory N. Britto, Esquire

Malcolm B. Savage, III, Esquire

William M. Savage, Esquire

Mary F. Balthasar Lake, Esquire

Leonard C. Tengco, Esquire

Shapiro & Brown, LLP Attorney for

Wells Fargo Bank, N.A.

501 Independence Parkway, Suite 203

Chesapeake, Virginia 23320

(703) 449-5800 13-235142

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UNITED STATES BANKRUPTCY COURT

EASTERN DISTRICT OF VIRGINIA

RICHMOND DIVISION

IN RE:

Michelle C Taylor

Debtor(s)

BCN#: 17-34844-KLP

Chapter: 13

OBJECTION OF U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR CREDIT 

SUISSE FIRST BOSTON MORTGAGE SECURITIES CORP., HOME EQUITY ASSET 

TRUST 2005-5, HOME EQUITY PASS-THROUGH CERTIFICATES, SERIES 2005-5

TO PROPOSED CHAPTER 13 PLAN AND

CONFIRMATION THEREOF

U.S. Bank National Association, as Trustee for Credit Suisse First Boston Mortgage 

Securities Corp., Home Equity Asset Trust 2005-5, Home Equity Pass-Through Certificates, 

Series 2005-5, and its assignees and/or successors in interest, a secured creditor in the aboveentitled Bankruptcy proceeding, hereby submits the following objections to the confirmation of 

the Chapter 13 Plan proposed by Debtor:

1. This objecting secured creditor is the beneficiary of a trust deed on property 

commonly known as 5701 BARNWOOD DRIVE, Richmond, VA 23234; the promissory note 

and deed of trust were attached to the proof of claim filed by the secured creditor.

2. The debtor is due for Principal and interest in the amount of $75,940.28, 

Prepetition fees in the amount of $6,366.39, an Escrow deficiency for funds advanced in the 

amount of $17,460.00, and a Projected escrow shortage in the amount of $1,367.56.

3. The proposed Plan does not set forth a reasonable schedule and time period for the 

payment of arrearages on the deed of trust.

4. The proposed Chapter 13 plan does not provide this objecting secured creditor 

with adequate protection or adequate security, according to Sections 362 and 1325(a) of the 

Code.

5. The Plan does not propose to pay the secured creditor's entire claim as shown in 

its proof of claim in the amount of $101,134.23.

/s/ Mary F. Balthasar Lake

Gregory N. Britto, Esquire

Malcolm B. Savage, III, Esquire

William M. Savage, Esquire

Mary F. Balthasar Lake, Esquire

Leonard C. Tengco, Esquire

Shapiro & Brown, LLP

501 Independence Parkway, Suite 203

Chesapeake, Virginia 23320

(703) 449-5800 13-235142

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CONCLUSION 

Any Chapter 13 Plan proposed by Debtors must provide for and eliminate the objections 

specified above in order to be feasible and to provide adequate protection to this objecting 

secured creditor. It is respectfully requested that confirmation of the Chapter 13 Plan as 

proposed by Debtor be denied.

WHEREFORE, secured creditor prays as follows:

1. That confirmation of the proposed Chapter 13 Plan be denied.

2. For attorney's fees and costs incurred herein.

3. That a hearing be held December 6, 2017, at 9:10 am at Judge Phillips' 

Courtroom, 701 E. Broad St., Rm. 5100, Richmond, Virginia. on this objection.

4. For such other relief as this Court deems proper.

Dated: November 1, 2017 Respectfully submitted

U.S. Bank National Association, as Trustee for Credit 

Suisse First Boston Mortgage Securities Corp., Home 

Equity Asset Trust 2005-5, Home Equity Pass-Through 

Certificates, Series 2005-5

By Counsel:

/s/ Mary F. Balthasar

Gregory N. Britto, Esquire

Malcolm B. Savage, III, Esquire

William M. Savage, Esquire

Mary F. Balthasar Lake, Esquire

Leonard C. Tengco, Esquire

Shapiro & Brown, LLP

501 Independence Parkway, Suite 203

Chesapeake, Virginia 23320

(703) 449-5800

I certify that I have electronically transmitted and/or mailed true copies of the above Objections 

to the Chapter 13 Plan, by First Class Mail, postage prepaid on this 1st day of November, 2017 to 

the following:

Pia J. North Suzanne E. Wade Michelle C Taylor

North Law P.O. Box 1780 5701 BARNWOOD DRIVE

5913 Harbour Park Drive Richmond, VA 23218-1780 Richmond, VA 23234

Midlothian, VA 23112

/s/ Mary F. Balthasar Lake

Gregory N. Britto, Esquire

Malcolm B. Savage, III, Esquire

William M. Savage, Esquire

Mary F. Balthasar Lake, Esquire

Leonard C. Tengco, Esquire

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