Bradley Jones (VSB No. 85095) 

Counsel for the Trustee 

ODIN FELDMAN & PITTLEMAN, P.C. 

1775 Wiehle Avenue, Suite 400 

Reston, Virginia 20190 

Phone: 703-218-2176 

Fax: 703-218-2160 

Brad.Jones@opflaw.com 

UNITED STATES BANKRUPTCY COURT 

FOR THE EASTERN DISTRICT OF VIRGINIA 

Alexandria Division 

In re: )

 ) 

JOE JULIAN GREEN and ) Case No. 18-12915-KHK 

GERALDINE SUSAN GREEN, ) Chapter 7

 aka Geraldine Susan Hanold )

 aka Geraldine Susan Biris )

 )

Debtors. )

 

NEW RESIDENTIAL MORTGAGE )

LOAN TRUST 2016-2 ) 

 ) 

Movant, )

 ) 

v. )

 ) 

JOE JULIAN GREEN and )

GERALDINE SUSAN GREEN ) 

 aka Geraldine Susan Hanold ) 

 aka Geraldine Susan Biris )

 ) 

and )

 ) 

DONALD F. KING, TRUSTEE )

 ) 

Respondents. )

ANSWER

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

for Relief From the Automatic Stay (the “Motion”) filed by New Residential Mortgage Loan 

Trust 2016-2 (“Movant”) in the above referenced case for the property located at 5400 Antioch 

Ridge Dr., Haymarket, VA 20169 (the “Property”), and states as follows: 

1. The Trustee admits the allegations contained in Paragraphs 1, 2, and 3. 

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

Paragraphs 4, 5, 6, and 7 of the Motion, neither admits nor denies such allegations and 

requires proof thereof. 

3. The Trustee admits the allegation in Paragraph 8 that there are multiple deeds 

of trust encumbering the Property but denies the allegation that there is not equity in the 

Property. 

4. The Trustee denies the allegations contained in Paragraphs 9 and 10 of the 

Motion. 

AFFIRMATIVE DEFENSE

Assuming, without admitting, that Movant’s allegations in the Motion are correct, there 

is a significant equity cushion protecting Movant’s alleged interest in the Property. Movant 

does not include any allegations regarding the current amount it is owed under its mortgage 

and deed of trust. But the allonge to its note indicates the original loan amount was only 

$465,000 and the Motion claims that the Debtors are only three months behind. See Dkt. No. 

12 at 4; Dkt. No. 12-1 at 23. According to the Debtors, the first mortgage is only $346,285.00. 

Dkt. No. 1 at 22. So there appears to be substantial equity. The Trustee is actively working to 

sell the Property and has received an estimate that the Property is worth about $700,000.00. 

The Property is thus worth significantly more than the amount necessary to pay Movant. 

Moreover, if the Property is sold, the Movant’s debt will be paid in full from any sale of 

the Property by the Trustee or on terms that are agreeable to the Movant. As a result, the 

Trustee believes that Movant’s alleged interests are adequately protected by the equity cushion 

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. 

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DONALD F. KING, TRUSTEE 

By Counsel 

By: /s/ Bradley Jones 

Bradley Jones (VSB No. 85095) 

 Counsel for Trustee 

 ODIN FELDMAN & PITTLEMAN, P.C. 

 1775 Wiehle Avenue, Suite 400 

 Reston, Virginia 20190 

 Phone: 703-218-2176 

 Fax: 703-218-2160 

 Brad.Jones@ofplaw.com 

 #4120314v1 31070/00001 

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CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a true and accurate copy of the Answer was sent via Notice 

of Electronic Filing upon counsel for Movant, counsel for Debtor, and all registered users in 

this case pursuant to this Court’s CM/ECF policy. 

/s/ Bradley Jones 

Bradley Jones 

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