Johnie R. Muncy, Esquire

Counsel for Plaintiff

Samuel I White, P.C.

Bar No. 73248

1804 Staples Mill Road

Suite 200

Richmond, VA 23230

(804) 290-4290

File No. 63983

OBJECTION TO CONFIRMATION OF CHAPTER 13 PLAN

NOTICE

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 SUSTAIN THE OBJECTION SOUGHT HEREIN, OR IF YOU WANT THE COURT 

TO CONSIDER YOUR VIEWS ON THE OBJECTION, THEN YOU MUST ATTEND THE HEARING ON THIS MATTER, 

OTHERWISE, THE COURT MAY DEEM OPPOSITION WAIVED, TREAT THE OBJECTION AS CONCEDED, AND ISSUE 

AN ORDER SUSTAINING THE OBJECTION WITHOUT FURTHER NOTICE OR HEARING.

THE HEARING IS SCHEDULED TO BE HELD ON JANUARY 17, 2019 AT 9:30 AM AT 

THE U.S. BANKRUPTCY COURT, JUDGE KINDRED’S COURTROOM, ALEXANDRIA 

DIVISION, 200 S. WASHINGTON STREET, ALEXANDRIA, VA 22314, IN COURTROOM 

NUMBER III, 3RD FLOOR.

COMES NOW, United Security Financial Corp. (“Secured Creditor”), by Counsel, and 

objects to the confirmation of the Chapter 13 Plan (the “Plan”) and in support thereof, represents 

unto the Court:

1. Secured Creditor has a claim against the property of the Debtor located at 11549 

Hearthstone Court, Reston, VA 20191 by virtue of the Note and accompanying Deed of Trust.

2. The pre-petition arrearage owed to Secured Creditor is approximately $36,907.44.

Secured Creditor is in the process of drafting and filing a Proof of Claim in the instant case.

3. The Plan is underfunded, as there is no provision for the pre-petition arrearage to 

be paid to Secured Creditor on the subject loan. The Plan also does not clearly indicate that regular 

monthly post-petition payments will be made to Secured Creditor as required.

4. Secured Creditor objects due to the aforesaid deficiencies in the Plan.

5. Any Chapter 13 Plan proposed by the Debtor must provide for and eliminate the 

objections specified above in order to be feasible and to provide adequate protection to this 

IN THE UNITED STATES BANKRUPTCY COURT

FOR THE EASTERN DISTRICT OF VIRGINIA 

ALEXANDRIA DIVISION

In re:

VALINDA MARIE DODSON

DBA VALINDA M DODSON MORTGAGE 

MARKETING,

CHAPTER 13

DEBTOR. CASE NO. 18-13714-KHK

Case 18-13714-KHK Doc 24 Filed 11/20/18 Entered 11/20/18 16:22:29 Desc Main

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Secured Creditor. It is respectfully requested that this Court deny confirmation of the Plan. 

WHEREFORE, the undersigned requests as follows:

1. That confirmation of the proposed Plan be denied;

2. Debtor be required to modify the Plan to honor the terms and conditions of the 

Deed of Trust; and

3. For such other relief as this Court deems proper. 

United Security Financial Corp.

By: /s/JOHNIE R. MUNCY

Eric D. White, Esquire, Bar No. 21346

Michael T. Freeman, Esquire, Bar No. 65460

Brandon R. Jordan, Esquire, Bar No. 72170

Johnie R. Muncy, Esquire, Bar No. 73248

Nisha R. Patel, Esquire, Bar No. 83302

Samuel I. White, P.C.

1804 Staples Mill Road

Suite 200

Richmond, VA 23230

Tel.: (804) 290-4290

Fax: (804) 290-4298

jmuncy@siwpc.com

CERTIFICATE OF SERVICE

I certify that on November 20, 2018, the foregoing Objection was served via CM/ECF on 

Thomas P. Gorman, Trustee, at the email addresses registered with the Court, and that a true copy 

was mailed via first class mail, postage prepaid, to Valinda Marie Dodson, Debtor, 11549 

Hearthstone Court, Reston, VA 20191.

/s/JOHNIE R. MUNCY

Johnie R. Muncy, Esquire

Samuel I. White, P. C.

Case 18-13714-KHK Doc 24 Filed 11/20/18 Entered 11/20/18 16:22:29 Desc Main

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