IN THE UNITED STATES BANKRUPTCY COURT

FOR THE EASTERN DISTRICT OF VIRGINIA

Norfolk Division

In re: STEVEN CHRISTOPHER TOWNSEND

JAE W TOWNSEND

Debtors

Chapter 13

Case No.: 18-70279-FJS

MOTION FOR DETERMINATION OF THE FINAL CURE PURSUANT TO RULE 3002.1

The Debtors' confirmed Plan provides that the Debtors shall make all post-petition payments directly to U.S. 

Bank National Association, the holder on the Note on the real property owned by the Debtors (the "Lender").

1.

NOW COMES Michael P. Cotter, Chapter 13 Trustee ("Trustee") and for his Motion for Determination of the Final 

Cure Pursuant to Rule 3002.1 and states as follows:

On or about June 28, 2022, the Trustee, in accordance with the requirements of Bankruptcy Rule 3002.1 (f), filed 

and served on the Lender a Notice of Final Cure Payment advising that the amount required to cure the 

pre-petition default claim 3 had been paid in full.

2.

3. On or about July 11, 2022, the Lender filed its Response to the Notice of Final Cure Payment and advised that it 

disagreed that all post-petition direct payments had been made by the Debtors. The total amount of 

post-petition arrears is $17,936.56 according to the Lender.

4. The Trustee is without specific knowledge relative to whether the Debtors have made the post -petition direct 

payments to the Lender and accordingly hereby requests that this Court conduct a Status Hearing to determine 

whether all necessary post-petition payments have been made, pursuant to Local Standing Order 16 -1, so that 

the Trustee may better evaluate his subsequent course of action.

WHEREFORE, the Trustee requests that a Status Hearing be conducted and that this Honorable Court determine 

whether all necessary post-petition payments have been made.

Michael P. Cotter

Chapter 13 Standing Trustee

/s/ Michael P. Cotter

Michael P. Cotter

VSB No. 19526

Chapter 13 Standing Trustee

870 Greenbrier Circle, Suite 402

Chesapeake, VA 23320

(757) 961-3000

Case 18-70279-FJS Doc 66 Filed 07/22/22 Entered 07/22/22 08:09:27 Desc Main

Document Page 1 of 2
IN THE UNITED STATES BANKRUPTCY COURT

FOR THE EASTERN DISTRICT OF VIRGINIA

Norfolk Division

In re: STEVEN CHRISTOPHER TOWNSEND

JAE W TOWNSEND

Debtors

Chapter 13

Case No.: 18-70279-FJS

NOTICE OF MOTION FOR DETERMINATION OF THE FINAL CURE

PURSUANT TO RULE 3002.1 AND NOTICE OF HEARING

NOW COMES Michael P. Cotter, Chapter 13 Trustee has filed a Notice of Motion for Determination of the Final 

Cure Pursuant to Rule 3002.1 and Notice of Hearing.

NOTICE IS HEREBY GIVEN that a HEARING on the foregoing Motion for Determination of the Final Cure will be 

convened on Wednesday, September 7, 2022 at 11:30 am. The hearing will held remotely and in accordance with 

Amended Norfolk/Newport News Standing Order 20-4. Any party wishing to appear must transmit a Zoom Request Form 

which is available on the Court's website at https://www.vaeb.uscourts.gov/sites/vaeb/files/ZoomRegistration.pdf two 

(2) business days prior to the hearing.

/s/ Michael P. Cotter

Michael P. Cotter

Chapter 13 Standing Trustee

I hereby certify that a copy of the foregoing Motion for Determination of the Final Cure Pursuant to Rule 3002.1 and Notice 

of Hearing was served on the parties listed below by ordinary U.S. Mail or served electronically through the Court’s ECF 

System at the e-mail address registered with the Court on this 21st day of July, 2022.

CERTIFICATE OF SERVICE

STEVEN CHRISTOPHER TOWNSEND, JAE W TOWNSEND, 3515 HUETTE DRIVE, NORFOLK, VA 23518

ELECTRONIC SERVICE - THE MERNA LAW GROUP, PC, 621 N LYNNHAVEN RD, VIRGINIA BEACH, VA 23452

RUSHMORE LOAN MANAGEMENT, PO BOX 55004, IRVINE, CA 92619-2708

TODD RICH, MCMICHAEL TAYLOR GRAY, LL, 3550 ENGINEERING DRIVE, SUITE 26, PEACHTREE CORNERS, GA 

30092

/s/ Michael P. Cotter

Michael P. Cotter

Chapter 13 Standing Trustee

Michael P. Cotter

VSB No. 19526

Chapter 13 Standing Trustee

870 Greenbrier Circle, Suite 402

Chesapeake, VA 23320

(757) 961-3000

Case 18-70279-FJS Doc 66 Filed 07/22/22 Entered 07/22/22 08:09:27 Desc Main

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