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 Debtor

IN THE UNITED STATES BANKRUPTCY COURT 

FOR THE EASTERN DISTRICT OF VIRGINIA 

Richmond Division 

 

IN RE: ) 

 ) 

JAMEO DEWAYNE POLLOCK ) Case No. 17-35895-KRH 

 ) Chapter 13 

 Debtor ) 

MOTION TO EXPEDITE HEARING ON MOTION 

TO INCUR DEBT AND TO SHORTEN NOTICE PERIOD 

 COMES NOW the Debtor, by counsel, and moves this Court to Expedite the Hearing on his 

Motion to Incur Debt and to Shorten Notice Period, and in support thereof states as follows: 

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

November 28, 2017. 

 2. The Debtor has applied for and Basic Auto Sales RVA has approved a loan to the 

Debtor in the amount of $27,140.89 plus interest at 16.75% per annum to be repaid with 72 equal 

monthly payments of $600.00 for the purchase of a 2018 Dodge Durango SXT or similar 

vehicle. 

3. The Debtor needs to purchase the referenced vehicle because Debtor’s current 

vehicle has broken down, and Debtor needs a replacement vehicle to travel to and from work. 

4. The purchase of the vehicle is in the best interest of the Debtor and will facilitate 

Debtor’s ability to perform under the Chapter 13 Plan filed herein. 

 5. The Debtor’s Chapter 13 Plan has been confirmed. 

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WHEREFORE, the Debtor respectfully requests that the Court expedite the hearing on 

their Motion to Incur Debt, Shorten the Notice Period required for said Motion, and for such other 

and further relief as is just and proper. 

Dated: September 21, 2021 JAMEO DEWAYNE POLLOCK 

 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 Debtor 

 

CERTIFICATION

 I, James E. Kane, pursuant to Local Rule 9013-1(N), do hereby certify that: 

 

 1. I have carefully examined the matter and concluded that there is a true need for 

an emergency hearing, 

 2. I have not created the emergency through any lack of due diligence. 

 3. I have made a bona fide effort to resolve the matter without hearing. 

By: /s/ James E. Kane__________ 

 James E. Kane 

Case 17-35895-KRH Doc 28 Filed 09/21/21 Entered 09/21/21 13:58:38 Desc Main

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CERTIFICATE OF SERVICE 

I hereby certify that on September 21, 2021, 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 will mail the same by first class mail, 

postage pre-paid, to the parties on the attached list. 

/s/ James E. Kane 

Counsel for Debtor 

Case 17-35895-KRH Doc 28 Filed 09/21/21 Entered 09/21/21 13:58:38 Desc Main

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IN THE UNITED STATES BANKRUPTCY COURT 

FOR THE EASTERN DISTRICT OF VIRGINIA 

Richmond Division 

 

IN RE: ) 

 ) 

JAMEO DEWAYNE POLLOCK ) Case No. 17-35895-KRH 

 ) Chapter 13 

 Debtor ) 

NOTICE OF MOTION AND HEARING 

 The above Debtor has filed papers with the Court to request an order to Expedite the 

hearing and to Shorten the Notice Period with respect to Debtor’s Motion to Incur Debt. 

 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 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 

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 September 22, 2021 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. 

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 REMOTE HEARING INFORMATION: 

Due to the COVID−19 public health emergency, no in-person hearings are being 

held. 

This hearing will take place remotely through Zoom on the date and time scheduled 

herein. 

To appear at the hearing, you must send, by email, a completed request form (the 

“Zoom Request Form”), which is available on the Court's internet website at 

www.vaeb.courts.gov, on the page titled, “Temporary Emergency Provisions 

Regarding ZoomGov Remote Proceeding Access Information.” Email your 

completed Zoom Request Form to the email address listed for the Judge assigned to 

the case. Following receipt of your Zoom Request Form, Court staff will respond to 

the email address from which the request was submitted with additional information 

on how to participate through Zoom. 

***The email address shall be used only to submit Zoom Request Forms. No other 

matters or requests will be considered by Court staff, and under no circumstances will 

any such matters or requests be brought to the Judge’s attention. Failure to comply 

with these instructions may result in appropriate action, including but not limited to 

the imposition of sanctions. 

*** PLEASE NOTE: You MUST submit the Zoom Request Form no later than 

two (2) business days prior to this hearing. Any documentary evidence the 

parties wish to present at the hearing must be filed with the Court in advance of 

the 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: September 21, 2021 JAMEO DEWAYNE POLLOCK 

 By: /s/ James E. Kane 

 Counsel 

Case 17-35895-KRH Doc 28 Filed 09/21/21 Entered 09/21/21 13:58:38 Desc Main

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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 Debtor 

CERTIFICATE OF SERVICE 

I hereby certify that on September 21, 2021, 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 will mail the same by first class mail, 

postage pre-paid, to the parties on the attached list. 

/s/ James E. Kane 

Counsel for Debtor 

Case 17-35895-KRH Doc 28 Filed 09/21/21 Entered 09/21/21 13:58:38 Desc Main

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Afni

Attn: Bankruptcy

Po Box 3097

Bloomington, IL 61702

Capital One

Attn: General Correspondence/Bankruptcy

Po Box 30285

Salt Lake City, UT 84130

Capital One Auto Finance

Attn: General Correspondence/Bankruptcy

Po Box 30285

Salt Lake City, UT 84130

Dept Of Ed/Navient

Attn: Claims Dept

P.O. Box 9635

Wilkes Barr, PA 18773

Dept Of Ed/Navient

Po Box 9635

Wilkes Barre, PA 18773

Focused Recovery Solutions

9701-Metropolitan Ct

Ste B

Richmond, VA 23236

Fst Premier

601 S Minneapolis Ave

Sioux Falls, SD 57104

Gerald Taylor

8500 Perrymont Road

Richmond, VA 23237

JL Walston & Associates

Attn: Bankruptcy

2609 N Duke St, Ste 501

Durham, NC 27704

Navient

Attn: Bankruptcy

Po Box 9500

Wilkes-Barr, PA 18773

Case 17-35895-KRH Doc 28 Filed 09/21/21 Entered 09/21/21 13:58:38 Desc Main

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Navient

Po Box 9500

Wilkes Barre, PA 18773

Receivables Performance Mgmt

Attn: Bankruptcy

Po Box 1548

Lynnwood, WA 98036

Title Max

4722 S. Laburnum Ave

Henrico, VA 23231

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