UNITED STATES BANKRUPTCY COURT 

FOR THE 

EASTERN DISTRICT OF VIRGINIA 

Alexandria Division 

In the Matter of: 

 Chapter 13

VIRGINIA TISINO

 Case No. 18-13960-BFK

 Debtor

OBJECTION TO CONFIRMATION OF PLAN, 

NOTICE OF OBJECTION TO CONFIRMATION OF PLAN 

AND 

NOTICE OF SCHEDULED HEARING ON THIS OBJECTION 

Thomas P. Gorman, Chapter 13 Trustee, has filed this objection to confirmation of 

your Chapter 13 Plan filed December 10, 2018. The cause for this objection is as 

follows: 

Violation of 11 U.S.C. §1325(a)(6) - Feasibility - Plan is underfunded as 

follows due to Commonwealth of Virginia, Department of Taxation (Claim 

No.10): 

PERFORMANCE Amount of Plan Payment 2550.87 

Number of Months 60 

Total Receipts 153,052.20

 Disbursements Required 

 Trustee 14,785.51 10.00%

Attorney 2,500.00 

Taxes/Other Priority 61,508.33 

Secured 1,658.75 

Unsecured 82,187.98 

Other

 Total Disbursements 162,640.57

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 wish the court to grant the relief sought in the objection, or if you 

want the court to consider your views on the objection, then on or before five business 

days prior to the hearing date, you or your attorney must: 

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Notice of Objection To Confirmation 

Virginia Tisino, Case # 18-13960-BFK 

File with the court a written response with supporting memorandum as required 

by Local Bankruptcy Rule 9013-1(H). Unless a written response and 

supporting memorandum are filed and served by the date specified, the Court 

may deem any opposition waived, treat the motion as conceded, and issue an 

order granting the requested relief without further notice or hearing. If you mail 

your 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. You must mail a copy to the 

persons listed below. 

Attend the hearing to be held on February 7, 2019 at 1:30 p.m. in Courtroom 

#1 on the 2nd floor, United States Bankruptcy Court, 200 South Washington 

Street, Alexandria, Virginia 22314. If no timely response has been filed 

opposing the relief requested, the court may grant the relief without holding a 

hearing. 

 A copy of any written response must be mailed to the following persons: 

 Thomas P. Gorman 

 300 North Washington Street, Ste, 400 

 Alexandria, VA 22314 

 Clerk of the Court 

 United States Bankruptcy Court 

200 South Washington Street 

Alexandria, VA 22314 

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

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

relief. 

Date: _January 25, 2019______ ___/s/ Thomas P. Gorman_____ 

 Thomas P. Gorman 

 Chapter 13 Trustee 

 300 N. Washington Street, #400 

 Alexandria, VA 22314 

 (703) 836-2226 

 VSB 26421 

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Notice of Objection To Confirmation 

Virginia Tisino, Case # 18-13960-BFK 

CERTIFICATE OF SERVICE 

I hereby certify that I have this 25th day of January, 2019, served via ECF authorized 

users or mailed a true copy of the foregoing Objection to Confirmation, Notice of 

Objection and Notice of Hearing to the following parties. 

Virginia Tisino 

Chapter 13 Debtor 

27 Rapidan Drive 

Stafford, VA 22556 

Ashvin Pandurangi 

Attorney for Debtor 

AP Law Group, PLC 

7777 Leesburg Pike, Suite 402N 

Falls Church, VA 22043 

 __/s/ Thomas P. Gorman______ 

 Thomas P. Gorman

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