UNITED STATES BANKRUPTCY COURT 

FOR THE 

EASTERN DISTRICT OF VIRGINIA

Alexandria Division

In the Matter of:

Chapter 13

DAMION D REEVES

AND

ZENA REEVES

Case No. 19-10889-KHK

Debtors

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 March 20, 2019. The cause for this objection is as follows:

Violation of 11 U.S.C. §1325(a)(3) – Good Faith and Violation of 11 U.S.C. 

§1325(b)(1)(B) – Disposable Income. Debtors’ Plan must be 100% due to 

disposable income. Their present disposable monthly income s $2,649.37/mo. 

per Schedule I/J, even with an investment property that loses money. There is 

no reason to defer the Plan funding via deferred step payment of $900.00/mo. to 

$1,795.00/mo. in month 42, and it puts creditors at risk. 

Violation of 11 U.S.C. §1325(a)(6) – Feasibility: 

1. Debtors have not yet provided filed 2018 tax returns. 

2. 100% Plan does not provide for Priority portion of filed Internal Revenue 

Service Proof of Claim (Claim #5) nor unsecured Homeowners Association 

(Claim #6) and is underfunded as follows: 

PERFORMANCE Amount of Plan Payment 900.00 x 41

1,795.00 x 19

Number of Months 60

Total Receipts 71,005.00

Disbursements Required

Trustee 8,381.12 10.00%

Attorney 2,500.00

Taxes/Other Priority 19,353.20

Secured 13,473.28

Unsecured 48,791.12

Other

Total Disbursements 92,192.36

Case 19-10889-KHK Doc 13 Filed 05/09/19 Entered 05/09/19 15:26:14 Desc Main

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Notice of Objection To Confirmation

Damion D Reeves and Zena Reeves, Case # 19-10889-KHK

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:

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 May 23, 2019 at 9:30 a.m., in Courtroom III 

on the 3rd floor, United States Bankruptcy Court, 200 South Washington 

Street, Alexandria, VA 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: _May 9, 2019______ __/s/Thomas P. Gorman ________

Thomas P. Gorman

Chapter 13 Trustee

300 N. Washington Street, #400

Alexandria, VA 22314

(703) 836-2226

VSB 26421

Case 19-10889-KHK Doc 13 Filed 05/09/19 Entered 05/09/19 15:26:14 Desc Main

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Notice of Objection To Confirmation

Damion D Reeves and Zena Reeves, Case # 19-10889-KHK

CERTIFICATE OF SERVICE

I hereby certify that I have this 9

th day of May, 2019, served via ECF to authorized 

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

Objection and Notice of Hearing to the following parties.

Damion D Reeves

Zena Reeves

Chapter 13 Debtors

9501 Mason Village Loop

#304

Manassas, VA 20109 

Michael J.O. Sandler

Attorney for Debtor

Fisher-Sandler, LLC. 

12801 Darby Brook Court, Suite 201

Woodbridge, VA 22192 

__/s/ Thomas P. Gorman______

Thomas P. Gorman

Case 19-10889-KHK Doc 13 Filed 05/09/19 Entered 05/09/19 15:26:14 Desc Main

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