H. Jason Gold, Va. Bar No. 19117

101 Constitution Avenue, NW, Suite 900

Washington, DC 20001

(202) 689-2800

Trustee

cIN THE UNITED STATES BANKRUPTCY COURT

FOR THE EASTERN DISTRICT OF VIRGINIA

Alexandria Division

In re: )

) Bankruptcy Case

MONICA N. SANTOS, ) No. 18-13067-BFK

)

Debtor. ) Chapter 7

__________________________________________)

WELLS FARGO BANK, NATIONAL )

ASSOCIATION, AS TRUSTEE FOR BANC OF )

AMERICA MORTGAGE SECURITIES, INC. )

MORTGAGE PASS-THROUGH CERTIFICATES,)

SERIES 2001-K )

)

Movant, )

)

v. )

)

MONICA N. SANTOS, )

)

Debtor, )

)

and )

)

KWASI A. KUBI, )

)

Codebtor, )

)

and )

)

H. JASON GOLD, )

)

Trustee, )

)

Respondents. )

TRUSTEE’S RESPONSE AND OPPOSITION TO MOTION FOR RELIEF FROM STAY 

COMES NOW, H. Jason Gold, the chapter 7 trustee (“Trustee”), and files this response 

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and opposition to the Motion for Relief from Automatic Stay (the “Motion”), stating to the Court 

as follows:

1. As reflected on Schedule A, the Debtors own real property commonly identified 

as 904 Royal Elm Court, Herndon, Virginia 20170 (the “Property”). 

2. The Section § 341 Meeting of Creditors was is scheduled for November 19, 2018. 

Until such time as the Trustee completes his investigation of the value of the Property and 

validity of the liens asserted against the Property, the Trustee opposes the relief from the 

automatic stay sought in the Motion.

3. The Trustee lacks sufficient information to form a response to the allegations in 

the Motion that cause exists to grant the relief sought in the Motion and therefore denies the 

same and demands strict proof.

4. UPON THE TRUSTEE’S FILING OF A REPORT OF NO DISTRIBUTION, 

THE MOVANT AND THE COURT MAY DEEM THE TRUSTEE’S OPPOSITION AS 

WITHDRAWN AND GRANT WHATEVER RELIEF THE COURT DEEMS APPROPRIATE.

WHEREFORE, having responded to the Motion, the Trustee prays (i) that the Court 

continue the hearing on the Motion until such time as the Trustee has had a chance to assess the 

value of the subject collateral and validity of the liens asserted against the subject collateral; (ii) 

that in the event that the Trustee files a Report of No Distribution, that the Trustee’s opposition 

be deemed withdrawn; and (iii) for such other and further relief as may be necessary.

Respectfully submitted, 

H. JASON GOLD, TRUSTEE

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H. JASON GOLD, TRUSTEE

101 Constitution Avenue, NW, Suite 900

Washington, DC 20001

Telephone: (202) 712-2800

Facsimile: (202) 712-2860

By: /s/ H. Jason Gold

H. Jason Gold, Va. Bar No. 19117

Chapter 7 Trustee

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on this 1

st day of November 2018 the foregoing Trustee’s 

Response and Opposition to Motion for Relief from Stay was served via Notice of Electronic 

Filing CM/ECF and pursuant to applicable Standing Order upon:

Mary Balthasar Lake

SHAPIRO & BROWN, LLP

501 Independence Pkwy, Suite 203

Chesapeake, VA 23320

Office of the US Trustee

1725 Duke Street, Ste. 650

Alexandria, VA 22314

Nathan A. Fisher 

Fisher-Sandler, LLC 

3977 Chain Bridge Road, #2 

Fairfax, VA 22030

Monica N. Santos

904 Royal Elm Court

Herndon, VA 20170

Kwasi A. Kubi

904 Royal Elm Court

Herndon, VA 20170

/s/ H. Jason Gold

H. Jason Gold

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