IN RE

ROSA TRENT STOKES

 Debtor

Case No. 19-31673-KLP

Chapter 7

MOTION FOR RELIEF FROM AUTOMATIC STAY

IN THE UNITED STATES BANKRUPTCY COURT

FOR THE EASTERN DISTRICT OF VIRGINIA

Richmond Division

SPECIALIZED LOAN SERVICING LLC

8742 Lucent Blvd.

Suite 300

Highlands Ranch, CO 80129

 Movant

v.

ROSA TRENT STOKES

200 Poplar Forest Rd

Apt D

Farmville, VA 23901

and

HARRY SHAIA, JR

CHAPTER 7 TRUSTEE

Spinella, Owings & Shaia, PC

8550 Mayland Drive

Richmond, VA 23294

 Respondents

Motion No.

 1. Jurisdiction is based on 11 U.S.C. Section 362(d)-(f).

 2. On or about March 28, 2019, Rosa Trent Stokes ("Debtor") filed a 

Voluntary Petition in the Court under Chapter 7 of the Bankruptcy Code.

 3. Harry Shaia, Jr is the Chapter 7 trustee of the Debtor's estate.

 4. At the time of the initiation of these proceedings, the Debtor owned a 

parcel of fee simple real estate improved by a residence with a legal description of 

"LAND REFERRED TO IN THIS COMMITMENT IS DESCRIBED AS ALL THAT 

CERTAIN PROPERTY SITUATED IN THE CITY OF CUMBERLAND IN THE 

 COMES NOW, Specialized Loan Servicing LLC, its successors and/or 

assigns, movant, by its attorneys, Mark D. Meyer, Esq., and Rosenberg & 

Associates, LLC, and respectfully represents as follows:

MARK MEYER

DC BAR 475552

MD BAR 15070

VA BAR 74290

ROSENBERG &

ASSOCIATES, LLC

 4340 East West Highway

SUITE 600

BETHESDA, MD 20814

(301) 907-8000

FILE NUMBER: 75122

Case 19-31673-KLP Doc 10 Filed 04/12/19 Entered 04/12/19 14:20:03 Desc Main

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COUNTY OF CUMBERLAND, AND STATE OF VIRGINIA AND BEING 

DESCRIBED IN A DEED DATED 03/10/1992 AND RECORDED 03/12/1992 IN 

BLOCK 188 PAGE 26 AMONG THE LAND RECORDS OF THE COUNTY AND 

STATE SET FORTH ABOVE, AND REFERENCED AS FOLLOWS: THAT 

CERTAIN PARCEL OF LAND IN MADISON MAGISTERIAL DISTRICT, 

CUMBERLAND COUNTY, VIRGINIA CONTAINING 0.79 ACRES, AS SHOWN ON 

PLAT OF SURVEY, MADE JANUARY 28, 1993, BY RALPH P. HINES, C.L.S., A 

COPY OF WHICH PLAT IS ATTACHED TO AND MADE A PART OF THIS DEED. 

THIS LOT IS THEREON DESCRIBED AS FOLLOWS: BEGINNING AT A POINT 

ON MARGIN OF STATE ROUTE 600, MARKED BY A SET IRON ONLINE, 

CORNER WITH VIRGINIA R. JENKINS, THENCE WITH SAID ROUTE 600 A 

CURVE, ARC 160.72', RADIUS 492.47', DELTA 18 DEGREES 41' 57" AND 

CHORD 160.01", S. 50 DEGREES 21' 55" E.; THENCE S. 15 DEGREES 02' 00" 

W. 227.30' TO A SET IRON WITH METAL FENCE POST; THENCE METAL N. 74 

DEGREES 58' 00" N. 128.00' TO A SET IRON WITH METAL FENCE POST; 

THENCE N. 11 DEGREES 37' 45" E. 294.43' ALONG CENTER OF OLD ROAD 

TO THE POINT OF BEGINNING, MARKED BY SAID SET IRON ON LINE AT 

281.9'. BEING A PORTION OFA 32 ACRE PARCEL PARTITIONED TO JAMES 

OTIS TRENT BY PARTITION DEED DATED JUNE 6, 1991, FROM LEE CRUMP, 

ET AL, WHICH DEED IS TO BE RECORDED IN THE CLERK'S OFFICE OF THE 

CIRCUIT COURT OF CUMBERLAND COUNTY, VIRGINIA PRIOR TO THIS DEED 

OF GIFT. COMMONLY KNOWN AS: 270 STONEY POINT RD, CUMBERLAND, 

VA 23040" also known as 270 Stoney Point Road, Cumberland, VA 23040 

(hereinafter "the subject property"). 

 5. The subject property is encumbered by a Deed of Trust securing the note, 

which is currently held by the movant. The documents evidencing the movant's 

security interest are attached hereto. 

 6. Specialized Loan Servicing LLC services the loan on the Property 

referenced in this Motion. In the event the automatic stay in this case is modified, 

this case dismisses, and/or the Debtor obtains a discharge and a foreclosure action 

is commenced on the mortgaged property, the foreclosure will be conducted in the 

name of Movant or Movant’s successor or assignee. Movant, directly or through an 

agent, has possession of the Note. The Note is either made payable to Movant or 

has been duly endorsed. Movant is the original mortgagee or beneficiary or the 

assignee of the Mortgage/Deed of Trust.

 7. The total amount due under the Deed of Trust securing the Movant as of 

April 9, 2019, including attorney's fees and court costs, is approximately $32,788.62.

 8. The Debtor is in default under the Deed of Trust, and the Movant has 

accelerated the entire balance of the Note and Mortgage and interest continues to 

accrue.

 9. The Debtor is behind in his/her monthly mortgage payments, and equity in 

the Debtor's residence is dissipating.

 10. The Movant lacks adequate protection of its interest in the subject 

MARK MEYER

DC BAR 475552

MD BAR 15070

VA BAR 74290

ROSENBERG &

ASSOCIATES, LLC

 4340 East West Highway

SUITE 600

BETHESDA, MD 20814

(301) 907-8000

FILE NUMBER: 75122

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 Document Page 2 of 4
property.

 11. The Movant has been and continues to be irreparably injured by the stay 

of Section 362 of the Bankruptcy Code, which prevents the Movant from enforcing 

its rights under the Note and Deed of Trust.

 12. Cause exists for lifting the automatic stay imposed by Section 362 of the 

Bankruptcy Code to enable the Movant to enforce its rights under its Note and 

Deed of Trust.

___________________________________

Mark D. Meyer, Esq.

VA Bar 74290 

Rosenberg & Associates, LLC

4340 East West Highway, Suite 600

Bethesda, MD 20814

301-907-8000

 WHEREFORE, the Movant, Specialized Loan Servicing LLC its successors 

and/or assigns, respectfully requests that this Honorable Court:

 1. Enter an order terminating the automatic stay imposed by Section 362 of 

the Bankruptcy Code to enable it to proceed with a foreclosure sale, accept a deed 

in lieu or agree to a short sale of the real property and improvements located at 270 

Stoney Point Road, Cumberland, VA 23040; and

 2. Grant such other and further relief as may be just and necessary.

/s/ Mark D. Meyer, Esq.

MARK MEYER

DC BAR 475552

MD BAR 15070

VA BAR 74290

ROSENBERG &

ASSOCIATES, LLC

 4340 East West Highway

SUITE 600

BETHESDA, MD 20814

(301) 907-8000

FILE NUMBER: 75122

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CERTIFICATE OF SERVICE

 I hereby certify that on the 12th day of April, 2019, I reviewed the Court’s 

CM/ECF system and it reports that an electronic copy of the foregoing Motion for 

Relief from the Automatic Stay will be served electronically by the Court’s CM/ECF 

system on the following:

___________________________________

Mark D. Meyer, Esq.

Harry Shaia, Jr, Trustee

Mary-Scott Gates Hennigan, Esquire

/s/ Mark D. Meyer, Esq.

 I hereby further certify that on the 12th day of April, 2019, a copy of the 

foregoing Motion for Relief from the Automatic Stay was also mailed first class 

mail, postage prepaid to:

Rosa Trent Stokes

200 Poplar Forest Rd

Apt D

Farmville, VA 23901

MARK MEYER

DC BAR 475552

MD BAR 15070

VA BAR 74290

ROSENBERG &

ASSOCIATES, LLC

 4340 East West Highway

SUITE 600

BETHESDA, MD 20814

(301) 907-8000

FILE NUMBER: 75122

Case 19-31673-KLP Doc 10 Filed 04/12/19 Entered 04/12/19 14:20:03 Desc Main

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