Sara A. John, VSB #48425 

M. Richard Epps, P.C. 

605 Lynnhaven Parkway 

Virginia Beach, Virginia 23452 

757-498-9600 

sara_john@eppspc.com 

Counsel for First Investors Financial Services

UNITED STATES BANKRUPTCY COURT 

EASTERN DISTRICT OF VIRGINIA

Richmond Division 

In re: ) 

 ) 

Shrika Detrice Tarrer ) 

) Case No. 18-33931-KLP 

) 

Debtor ) Chapter 13 

) 

Address 408 Pulaski Ave ) 

Richmond, VA 23222 ) 

 ) 

Last four digits of Social Security or Individual ) 

Tax-payer Identification (ITIN) No(s).: 3681 ) 

NOTICE OF OBJECTION TO CONFIRMATION 

First Investors Financial Services has filed papers with the court to object to the 

confirmation of the Chapter 13 plan filed by the Debtor. 

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 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. 

Clerk of Court 

United States Bankruptcy Court 

701 East Broad Street, Suite 4000 

Richmond, VA 23219

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You must also mail a copy to: 

 Sara A. John 

 M. Richard Epps, P.C. 

 605 Lynnhaven Parkway 

 Virginia Beach, VA 23452. 

□ Attend the hearing on the objection scheduled to be held on October 10, 2018 at 

9:10 AM at United States Bankruptcy Court, 701 East Broad Street, Room 5100, 

Richmond, Virginia. 

If you or your attorney do not take these steps, the court may decide that you do not 

oppose the relief sought in the objection and may enter an order granting that relief. 

 

Date: August 28, 2018 Signature, name, address and telephone number 

of person giving notice: 

 /s/ Sara A. John

 Sara A. John 

 M. Richard Epps, P.C. 

 605 Lynnhaven Parkway 

 Virginia Beach, VA 23452 

 757-498-9600 

 Virginia State Bar No. 48425 

Counsel for First Investors Financial Services 

Certificate of Service

 I hereby certify that on August 28, 2018 I mailed or electronically served a true copy of 

the foregoing Notice of Objection to: Shrika Detrice Tarrer, 408 Pulaski Ave, Richmond, VA 

23222; Suzanne E. Wade, Trustee, P.O. Box 1780, Richmond, VA 23218; and Veronica D. 

Brown-Moseley, Counsel to Debtor, P. O. Box 11588, Richmond, VA 23230. 

 /s/ Sara A. John

 Sara A. John 

 M. Richard Epps, P.C. 

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Sara A. John, VSB #48425 

M. Richard Epps, P.C. 

605 Lynnhaven Parkway 

Virginia Beach, Virginia 23452 

757-498-9600 

sara_john@eppspc.com 

Counsel for First Investors Financial Services

UNITED STATES BANKRUPTCY COURT 

 EASTERN DISTRICT OF VIRGINIA 

 Richmond Division 

In re: 

Shrika Detrice Tarrer Case No. 18-33931-KLP 

 Debtor. Chapter 13 

OBJECTION TO CONFIRMATION

 NOW COMES First Investors Financial Services and for its Objection to Confirmation to 

the Chapter 13 plan filed by Debtor herein states as follows: 

1. That Debtor filed a petition for relief under Chapter 13 on August 1, 2018. Debtor has filed 

a Chapter 13 plan. 

2. That First Investors Financial Services is the holder of a secured claim of Debtor secured by 

a purchase money security interest in a 2010 Mercedes-Benz E Class E350, VIN 

WDDHF8HB7AA146855 (the “vehicle”). The payoff at the time of filing is $20,485.17. This debt 

was incurred on August 29, 2016, a time within 910 days preceding the date of the filing of the 

petition in bankruptcy. 

3. That the plan states the value of the vehicle to be $15,450.00 and proposes to pay that sum as 

secured together with interest at the rate of 6.0%. 

4. That 11 U.S.C. § 1325 (a) provides in part that § 506 shall not apply in determining the 

amount of an allowed secured claim if the creditor has a purchase money security interest that is the 

subject of the claim, the debt was incurred within the 910 days preceding the filing of the petition, 

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and the collateral consists of a motor vehicle acquired for personal use of the Debtor. All three of 

these conditions are applicable to the indebtedness owed to First Investors Financial Services. 

5. That the plan provides for adequate protection monthly payments to be made to First 

Investors Financial Services in the amount of $75.00, which is less than 1% of the amount of First 

Investors Financial Services’s claim and which is an insufficient provision for adequate protection as 

required by 11 U.S.C § 1326. First Investors Financial Services requests adequate protection 

monthly payments of not less than $200.00. 

6. That First Investors Financial Services does not have evidence of insurance on the vehicle. 

7. That for the above-stated reasons, the plan does not comply with the provisions of Section 

1325 of the Bankruptcy Code. 

 WHEREFORE, First Investors Financial Services prays that confirmation of the Chapter 

13 plan submitted by Debtor herein be denied. 

 

 First Investors Financial Services 

 

 /s/ Sara A. John 

 Sara A. John 

 M. Richard Epps, P.C. 

Certificate of Service

 I hereby certify that on August 28, 2018, I mailed or electronically served a true copy of 

the foregoing Objection to: Suzanne E. Wade, Trustee, P.O. Box 1780, Richmond, VA 23218; 

Veronica D. Brown-Moseley, Counsel to Debtor, P. O. Box 11588, Richmond, VA 23230; and 

Shrika Detrice Tarrer, 408 Pulaski Ave, Richmond, VA 23222. 

 /s/ Sara A. John

Sara A. John 

 M. Richard Epps, P.C. 

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