Case 1:16-cv-01335-JCC-MSN Document 1 Filed 10/24/16 Page 1 of 5 PagelD 1 

FILED 

IN THE UNITED BANKRUPTCY COURT 

FOR THE EASTERN DISTRICT OF VIRGINIA 

Alexandria Division , lOlL OCT 

24 AlI:21 

RODNEY P. HUNT ) ARLINGTON COUN~C31RJCTCOURi 

) COURT CASE NO: G~t\Ja'IRGINIA Plaintiff, ) 

) BANKRUPTCY CASE NO: 15-13962 

V.	 ) 

) 

) NOTICE OF REMOVAL 

And ) OF STATE ACTION 

) 28 U.S.C 1331, et al. 

) 

201 CHAIN BRIDGE ROAD, LLC ) 

) /."/(PtY /335 

) J{~/A1~AI Defendants.	 ) 

----------------) 

NOTICE OF REMOyAL TO UNITED STATES BANKRUPTCY COURT 

To all parties, Arlington County District Court ofthe Commonwealth ofVirginia and 

counsel, take notice that this entire matter has been Removed into this UNITED BANKRUPTCY 

COURT FOR THE EASTERN DISTRICT OF VIRGINIA. The entire state court'sfile noted as 

Case No.: GV16003602-00 will be Exhibit 1 to the Removal. 

1. Said Removal shall divest and disqualify the Virginia State- General Court from taking 

any further action in the underlying case for want to jurisdiction under 28 U.S.C. 1331, et al and 

FRCP Rule 11. A stay on the State Court proceedings now exists. 

2. A formal determination ofreal property rights are in issue in this action and must be 

adjudicated as a condition precedent to a determination under the state case referenced. The 

potential for double inconsistent judgements in two forums exists. There is a soon to be filed 

federal case the core issue of which will be the egregious misconduct of Daniel M. Press the 

attorney for Plaintifffor failure to defend the DebtorlPlaintiff assets and complete disregard in 

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opposing a Motion of Relief filed by Bank ofAmerica, N.A. and Bank of America for selling 

his property at a foreclosure sale for a price below the market and 201 Chain Bridge Road, LLC 

for proceeding for an unlawful detainer action in clear violation of bankruptcy law. All the 

defendants in this actions orchestrated the illegal taking ofthe property belonging to Plaintiff via 

a corrupt foreclosure sale, uncontested motion for relief despite plaintiffhaving legal 

representation which included the failure to defend the motion for relief filed by Bank of 

America and notify or serve Plaintiffwith any notices, warnings or legal actions required under 

bankruptcy statues and fiduciary duty ofPlaintiff's attorney infonn his client and the effect of 

this misconduct as causing defendants to be deprived of his property and livelyhood in violation 

ofthe 5th and 14th Amendments to the U.S. Constitution without a scintilla of due process which 

has caused him extreme and outrageously inflicted distress, harm and injury and violated other 

federal statutes including Bankruptcy Law Violations, Civil rights Discrimination, Fair Debt 

Collection Practices Act and Fair Credit Reporting Acts and Legal Misrepresentation. The 

action will sound loud bankruptcy violations as its core theme. 

All the defendants conspired to take his property by taking advantage the Debtor in this case 

was incarcerated and his attorney did not inform him ofthe pending actions in his bankruptcy 

case. There are also serious questions as to why the trustee ofthe bankruptcy estate allowed a 

property worth more than 27 millions to be sold for just 9 million dollars, on that ground alone 

merits this case be removed and be decided in this bankruptcy court. 

3. Plaintiff further seeks an injunction staying any and all actions of creditors, or 

interested parties that are listed herein and are the subject premises for the pending action and 

determination by this bankruptcy court. 

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4. The issues in that action materially affect the case now Removed and hence should be 

consolidated with this matter in the interest if expeditious handling and to avoid conflicting 

outcomes in several different forums. The removing party requests that the court take judicial 

notice ofthis Related AdioD for all purposes upon filing ofthat anticipated matter within a 

period ofapproximately three to four weeks. 

5. Plaintiff has dismissed his counsel Daniel M. Press to represent him in this matter and 

is further precluded from making any representation on behalf of Plaintiff in any court. 

6. Previously this ARLINGTON COUNTY DISTRICT COURT CASE NO: 

GV16003602-00 was removed the United States Bankruptcy Court for the Eastern District of 

Virginia, counselor Daniel M. Press erroneously infonned the court that Plaintiff Rodney P. 

Hunt did not sign the motion and the case was dismissed. 

7. Within the civil complaint referenced in paragraph 2t abovet material issues exist bear 

on the plaintiffs ability to assert rights within the Removed case. Plaintiff in this new matter will 

asserted various claims and remedies based on promises and contractual obligations between 

plaintiff and defendants which were alleged to have been breached all to defendants' joint and 

several and individual detriment and injury. Defendants in this actiont cannot properly litigate 

this new matter to its fullest if the underlying Removed mattert which under Virginia scheme of 

law does not fairly allow full litigation of title disputes and issues including the ''taking of 

property without due process oflaw't envisioned within the 5th and 14d1 Amendments, attendant 

to sucht nor the further issues ofprovable prior and subsequent title to real property, legal 

standing and contractual breaches which have harmed plaintifft which if proven would form the 

basis for a rescission and setting aside ofthe foreclosure. Plaintiff in this secondary action will 

seek to reverse the conveyance loss of his primary residencet a single family home and a unique 

asset worth millions ofdollars. Ifproved, the state court action against Rodney P. Hunt would 

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•
 

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render the sale reversed and this underlying action would be deemed moot by operation of the 

law for want of title. Thus, this honorable court has much to gain by processing both matters in 

the due course of litigation which would resolve the conflicts and injuries alleged, under one 

federal roof. 

8. No parties will be prejudiced by this delay in prosecuting the Removed matter. 

Pursuant to procedural requirements the entire Removed action file contents are attached as 

Exhibit 1 to this Notice with Certificate of Service upon the State Court. 

9. Sufficient ground exists for this Removal as set forth in the Civil Case Cover Sheet 

under Grounds for Removal. The defendant 201 CHAIN BRIDGE ROAD, LLC., herein is a 

company whose situs and residency or place of business is in California, thus the matter may be 

removed on Diversity basis. This matter concerns the questionable conduct Plaintiff's attorney 

and bankruptcy trustee representing the Debtor 

October 24, 2016 

i 

Rodney P. Hunt, aefendant, pro se 

STATE OF VIRGINIA, At Large 

County of Fairfax, to wit: 

I, the undersigned NOTARY PUBLIC in and for the State and County aforesaid, do 

hereby Certify that RODNEY P. HUNT whose name is signed to the foregoing documents, 

dated has acknowledged the same before me in my State and County aforesaid. 

Given under my hand and seal this 24th day of October 2016 

MARWA M. AHMED 

Nolary Public
 

Commonwealth of Virginia
 

7520991
 

My Commission Exc"es Noy 30, 2016
 ".~"""~~":~.~"'."J" -t'~:,.,.."t'III:tj"""'; , ..... 

PUBLC 

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Case 1:16-cv-01335-JCC-MSN Document 2 *SEALED* Filed 10/24/16 Page 1 of 2 PagelD 

7 

AO 2.~0 (Rev. 07/10) Application to Proceed in District Court Without Prepaying Fees orCosts (Short Form) 

UNITED STATES DISTRICT Co ~.~~ 1~::'\1
 furilie I 

Eastern District of Virginia . G' OCT 24 2016 I j 

RODNEY ) CLERK, (' r;. D'~"'...;;, -:,.:"uAT P. HUNT ..---- ALEXAND VI GIN. 

Plaintiff/Petitioner ) 

v. ) Civil Action No. (:f!,t.V 1$:3~... ::rec..(M$,J 

201 CHAIN BRIDGE ROAD, LLC )
 

Defendant/Respondent )
 

APPLICATION TO PROCEED IN DISTRICT COURT WITHOUT PREPAYING FEES OR COSTS 

(Short Form) 

I am a plaintiffor petitioner in this case and declare that I am unable to pay the costs ofthese proceedings and 

that I am entitled to the relief requested. 

In support ofthis application, I answer the following questions under penalty ofpeljury: 

1. Ifincarcerated. I am being held at: . .. .... _ . 

If employed there, or have an account in the institution, I have attached to this document a statement certified by the 

appropriate institutional officer showing all receipts, expenditures, and balances during the last six months for any 

institutional account in my name. I am also submitting a similar statement from any other institution where I was 

incarcerated during the last six months. 

2. Ifnot incarcerated. If! am employed, my employer's name and address are: f 

I/lIJt p.-., I'I~ 'l'~ I f1~I'S""" 1/7 I;' /;Ii-V!< J.-~(J i~ 7' G IJvA 

/ tJ=-{r ,po J>- /3 tf b.JMy gross payor wages are: $ . ._ Q..9.Q. ' and my take-home payor wages are: $ ......_._".. _. per 

(specify pay period) 

3. Other Income. In the past 12 months, I have received income from the following sources (check all that apply): 

(a) Business, profession, or other self-employment a Yes erNo 

(b) Rent payments, interest, or dividends a Yes e1'No 

(c) Pension, annuity, or life insurance payments DYes rlJNo 

(d) Disability, or worker's compensation payments DYes eJNo 

(e) Gifts, or inheritances DYes efNo 

(f) Any other sources DYes 0No 

Ifyou answered "Yes" to any question above, describe below or on separate pages each source ofmoney and 

state the amount that you received and what you expect to receive in the future. 

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8 

AO]40 (Rev. 07/(0) Application to Proceed in District Court Without Prepaying Fees or Costs (Shon Fonn) 

4. Amount ofmoney that I have in cash or in a checking or savings account: $ __ 

5. Any automobile, real estate, stock, bond, security, trust, jewelry, art work, or other fmancial instrument or 

thing of value that I own, including any item ofvalue held in someone else's name (describe the property alld irs approximate 

value): 

6. Any housing, transportation, utilities, or loan payments, or other regular monthly expenses (describe lllId provide 

the amount ofthe monthly expense): 

13-~ Ii?> If)..o 

p,," t &() 0 

tr~(c1'" b-R) it) 0 

. 0 00 

7. Names (or, ifunder 18, initials only) of all persons who are dependent on me for support, my relationship 

with each person, and how much I contribute to their support: 

A/01 ( 

8. Any debts or financial obligations (describe the amounts owed and /0 whom they are payable): 

Declaration: I declare under penalty ofperjury that the above information is true and understand that a false 

::::mentmay result in adismissal ofmy claims _.__ ;jg£ _ {':>6-r/h 

---.:;;? Ap icant's _ I -L 

(I CJl::/··.Jedn, ~J.-j -(-­

"._-------_._-----. ----- -- --".. _.. .. 

Print name 

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CLOSED 

U.S. District Court
 

Eastern District of Virginia - (Alexandria)
 

CIVIL DOCKET FOR CASE #: 1:16-cy-Q1335-JCC-MSN
 

Internal Use Only 

Hunt v. 201 Chain Bridge Road, LLC Date Filed: 10/24/2016 

Assigned to: District Judge James C. Cacheris Date Terminated: 10/27/2016 

Referred to: Magistrate Judge Michael S. Nachmanoff Jury Demand: None 

Case in other court: Arlington County District Court, GV Nature of Suit: 220 Real Property: 

16003602-00 Foreclosure 

Cause: 28:1441 Notice of Removal Jurisdiction: Federal Question 

Plaintiff 

Rodney P. Hunt represented by	 Rodney P. Hunt 

201 Chain Bridge Road 

McLean, VA 22101 

PROSE 

Defendant 

201 Chain Bridge Road, LLC 

Date Filed # Page Docket Text 

10/24/2016 1 2 NOTICE OF REMOVAL from Arlington County District Court, case number 

GV 16003602-00 filed by Rodney P. Hunt. (Attachments: #.1 Civil Cover 

Sheet)(pmil,) (Entered: 10/26/2016) 

10/24/2016 8 MOTION for Leave to Proceed in forma pauperis by Rodney P. Hunt. (pmil, ) 

(Entered: 10/26/2016) 

10/27/2016 J. 10 ORDER - It is accordingly ORDERED that the case be TRANSFERRED to 

the United States Bankruptcy Court for the Eastern District of Virginia, 

Alexandria Division. The Clerk of this Court is directed to transfer all pleadings 

filed in this case and a copy of the docket sheet to the Clerk of the United States 

Bankruptcy Court for the Eastern District of Virginia, Alexandria Division. 

Signed by District Judge James C. Cacheris on 10/27/16. (gwalk, )(c/s) 

(Entered: 10/27/2016) 

10/28/2016 11 Case transferred to United States Bankruptcy Court for the Eastern District of 

Virginia - Alexandria Division. (pmil,) (Entered: 10/28/2016) 

Case 16-01199-RGM Doc 1 Filed 10/28/16 Entered 10/28/16 14:28:19 Desc Main

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----- ------ -------

Case 1:16-cv-01335-JCC-MSN Document 1-1 Filed 10/24116/)'~~}/J~?J~ag'~!M~ JS 44	 (Rev. 08116) CIVIL COVER SHEET 

The JS 44 civil cover sheet and the information conlained herein neither replace nor supplement the filing and service of pleadings or other papers as required by law except8S 

provided b~ I~I. rules of.cC;KUt. This fonn, approved by theJudicial Conference oftile United States in September 1974, is requIred for the use oftlle Clerk ofCoun lor the 

purpose ofimtlatJng the CIVIl docket sheet. (SEE INSTRUCTIONS ON NF.XT PAGI;' OF THIS FORM.) 

I. (a) PLAINTIFFS DEFENDANTS 

RODNEY P. HUNT 201 CHAIN BRIDGE ROAD, LLC 

(b) County of Residence of First Listed Plaintiff "-'-,;;.;..;.:....:....::..:..._----­ FAIRFAX County of Residence of First Listed Defendant ARLINGTON

(£XCIiPT IN U.S. PLAINTIFF CAS/;'S) (IN U.S.I'LAINTIFFCASESONI.Y) 

NOTE:	 IN LAND CONDEMNATION CASES, USE TIlE LOCATION OF 

THE TRACT OF LAND INVOLYEO. 

(e) Attorneys (Firm NOllie. AcJdres.•• a"d Telephone Numher) Attorneys (IfK""",,,)

II. BASIS OF JURISDICTION (I'lacea" "X"lnO"./JoxO"lyj III. CITIZENSHIP OF PRINCIPAL PARTIES (Place on "X" 1,,0'111 Ho.,jarl'lalnl!ff 

(For DI""rslty Casu Only) a.ld One Hn.y jar IJcpndoll/) 

o I u.s. Government 3 Federal Question PTF DEF PTF DEF 

PlaintifT (U.s. GOWIn,melll NOI a I'arty) Citizcn ofntis SCale (JI. I 0 I IlICOIpOllIIed or Principal Place 0 4 (JI. 4 

of Bu.inc.. [n This State 

o 2	 U.S. Government o 4 Diversity Citizen of Another SllIte o 2 0 InCO/POrated ami Principal Plocc o os

Defendant (Indicate Cl/ize/l.mlp ofI'arlies I/lirem III) ofBusin... In AnOlher Sr.te

Citizcn or Subject ofa o a Foreisn NlIlion o 6 06 

Forei Coun 

IV, NATURE OF SUIT (Place an "X" In OM/JoxO,	 Click here for: Nature of 

o 110 fnSUlal1CC PERSONAL INJURY PERSONAL INJURY 0 62501118 Related Seizure a 422 Appeal 28 USC 158 0 375 False Claitns Act 

o 120 Marine a 310 Airplane 0 365 Personal Injury • of Propcny 21 USC 881 a 423 Withdrawal 0 376 Qui Tam (31 USC 

o 130 Miller Aet 0 315 Airplane Product Product Liability 0 690 Other	 28 USC 157 3729(a» 

o 140 NegOliable Instrument Liability 0 367 Health Carel	 "!i!iWl~iiiiIi1Dmiiiii1 0 400 SllIle Reapportioom,ent a	 I so Reeovery ofO""rpaymenl 0 320 Assault. Libel &; Phannaccutical i!i 0 410 Amitrust
 

&. Enf~l ofJudgment Slander Penonal Injury a 820 Copyrishts 0 430 Bank. and Banltio'll
 

o 15 I Medicare Aet 0 330 Federal Employcn' Product Liability	 0 830 l'lIIent 0 450 COfnmen:e 

o 152 Recovery of Defaulted Liability 0 368 Asbestos Personal 0 840 Trade..at1< 0 460 DeponDlion 

Student Loans 0 340 Marine Injury Product ~~~~~il1iil!~!!!!§i~~~~~~~imli!li!l 0 470 Racketeer Inlluenc:ed and (Excludes Ve.Cl'IlIlS) 0 345 Marine Product Liability 	 CDmlpl Otallli2lllions 

o 153 RecovcryofOverpayment Liability PERSONAL PROPERTY 07l0FairLaborSIlIIIdanIs 0861 HIA(1395ff) 0480ConsunlCfCredil
 

o{Vctcran's Benefits 0 350 Molor Vdticle 0 370 Other Fraud Act 0 862 Black Lun8 (923) 0 490 CablelSaI TV
 

o 160 Stockholders' Suits a 355 Molor Vehiele 0 371 Trudl in Lending 0 720 LaborIM&I1Igemant 0 863 DIWClDIWW (405(g» a 856 Scc:uritietlCommoditiesl 

o 1900thcrContraet ProductUability 0380OtherPcrsonai Relations o 864 SSIDTitle XVI Exchange 

o 195 Contnet Produet Liability 0 360 Other Personal Propctty Oamaae 0 740 Railway Labor Act CJ 865 RSI (405(g» CJ 890 Odter Stalutory ActiOlIS 

o 196 Franehisc Injury o 385 PropenyDamage CJ 751 Family and Medical	 0891 AgrieulturalAets 

o 362 PcrsonaIlnjury • Produet Liability Leave Act	 0 893 Environmental MaI.ers 

~!!!!!Bii1gJmi[i!miSfi!ili¢iJ!!~M~cdiJj·lJ]eaI~Mii·i""i!P!!mg!iimi]ji1im.O 790 Other Labor LitiS".ion 9iiiiimi!iii!l~!§iiii~iI 0 895 Freedom oflnfon...ion ~i!~	 fR~ :fl:PAOP.E 0 791 Employee Rctiramcm I!! 'IIQ Ac. 

o 210 Land Condemnation 0 440 Other Civil Rights Habds Corpus, Income Security Ac. 0 870 Taxcs(U.S. PlaintifT 0 896 Arbitnuion 

M. 220 Foreclosurc 0 441 Voti"ll 0 463 Alien Detainee	 or Defendant) 0 899 Admini.trntive Procedure 

o 230 Rent Lease&. EjeclIlICII' 0442 Employlnent 0 510 Modons to V_te	 CJ 871 IRS-Third PIny Ac:tIRe\'icw or Appeal of 

o 240 Toni 10 Land 0 443 Housinst Senlau:e 26 USC 7609 AtJcney Dec:isiCM' 

a 245 Ton Prod"ct Liability Aec:ommodation. 0 530 General 0 956 Consti.utionality of 

o 290 All Other Real Property 0 445 Amer. wlDisabililiu­ 0 535 D..dI Penalty Stale Statutes 

Employment Otben o 462 NaIUrIIlization Applicalion 

o 446 Amer. wlDisabmtics· a 540 Mandamus &. Other o 46S Other Immigration 

Other 0 556 Civil Rishts Actions 

o 448 Education 0 5S5 Prison Condition 

CJ 560 Civil DcIlIince • 

Conditions of 

Confinement 

V. ORIGIN (Pla~"X.lnoneB'lJ(Only)

LI	 I Original . Removed from CJ 3 Remanded from LI 4 Reinslated or CJ 5 Transferred from CJ 6 Multidistrict CJ 8 Multidistrict 

Proceeding Slate Court Appellate Court Reopened	 Another District Litigation - Litigation ­

(s cl Transfer Direct File 

Cite the U.S. Civil Statute under which you are filing (On.ltIl citejl<tVdktkmll,.tlltUter 1I1f1_ dlV<tnlly): 

VI. CAUSE OF ACTION J."B-ri,...ef"..d"..es-c""'rip,-t"'"io-n-o""fca-us-e:--------------------------------­

FRAUD UPON U.S. BANKRUPCY COURT 

CHECK YES only ifdemanded in complain.: VII. REQUESTED IN o CHECK IF THIS IS A CLASS ACTION DEMAND S 

UNDER RULE 23, F.R.Cv.P. JURY DEMAND: LI Ves lJ No COMPLAINT: 

VIII. RELATED CASE(S) (See inslt'UCllolL.): DOCKET NUMBER IFANV	 JUDGE 

SIGNATURE OF AITORNEY OF RECORD DATE 

t'OR OFFICE USE ONLY 

JUDGE MAG. JUDGE RECEIPT. AMOUNT _ APPLYING IFP 

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CERTIFICATE OF SERVICE OF NOTICE OF REMOVAL ON STATE
 

COURT AND COUNSEL
 

On October 24, 2016, I jointly served the State Court from which this instant Removed 

action was taken and serve a copy of this Notice ofRemoval and also upon attorney for the 

plaintiff as follows: 

Counselfor Defendant 

201 Chain Bridge Road, LLC
 

Stephen Christenson
 

4160 Chain Bridge Road
 

Fairfax, Virginia 22030
 

Counselfor Defendant 

Daniel M. Press
 

Chung & Press, P.C.
 

6718 Whittier Ave., Suite 200
 

McLean, VA 22101
 

In his personal capacity 

Janet M. Meiburger
 

Bankrupcy Trustee
 

The Meiburger Law Firm, P.C.
 

1493 Chain Bridge Road, Suite 20 I
 

State Court served by Personal Service: 

Arlington County General District Court - Clerk of the Court
 

1425 N Courthouse Rd
 

Arlington, VA 22201
 

I declare under penalty of perjury that the forgoing is true and correct. Executed on 

August 24, 2016 

/ 

.c6t

Rodney P. Hunt, 

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