___________________________ 

Andrew Todd Rich, VSB# 74296 

8100 Three Chopt Rd., Suite 240 

Richmond, VA 23229 

(804) 282-0463(Phone)

Attorney for the Movant

UNITED STATES BANKRUPTCY COURT 

FOR THE EASTERN DISTRICT OF VIRGINIA

Richmond Division 

IN RE: 

ALONZO LEE BONNER, SR. 

SHIRLEY HARRIS BONNER 

Debtors 

_______________________________ 

WILMINGTON SAVINGS FUND SOCIETY, FSB, D/B/A 

CHRISTIANA TRUST, NOT INDIVIDUALLY BUT AS 

TRUSTEE FOR PRETIUM MORTGAGE ACQUISITION 

TRUST 

Movant 

v. 

ALONZO LEE BONNER, SR. 

SHIRLEY HARRIS BONNER 

Debtors/Respondents 

and 

SUZANNE E. WADE 

Trustee/Respondent 

Case No. 16-35775-KLP 

Chapter 13 

MOTION FOR RELIEF FROM AUTOMATIC STAY 

Wilmington Savings Fund Society, FSB, d/b/a Christiana Trust, not individually but as 

Trustee for Pretium Mortgage Acquisition Trust (“Movant”) hereby moves this Court, pursuant 

to 11 U.S.C. § 362, for relief from the automatic stay, with respect to certain real property of the 

Debtors having an address of 208 Holly Hill Drive, Petersburg, VA 23805 (the “Property”), for 

all purposes allowed by the Note (defined below), the Deed of Trust (defined below), and 

applicable law, including but not limited to the right to foreclose. In further support of this 

Motion, Movant respectfully states: 

1. The Court has jurisdiction over this matter pursuant to 28 U.S.C. §§ 1334 & 157.

2. A petition under Chapter 13 of the United States Bankruptcy Code was filed with

respect to the Debtors on November 23, 2016. 

3. A Chapter 13 Plan was confirmed on March 23, 2018.

4. The Debtors have executed and delivered or are otherwise obligated with respect

to that certain promissory note in the original principal amount of $67,500.00 (the “Note”). A 

copy of the Note is attached hereto. Movant is an entity entitled to enforce the Note. 

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5. Pursuant to that certain Deed of Trust (the “Deed of Trust”), all obligations 

(collectively, the “Obligations”) of the Debtors under and with respect to the Note and the Deed 

of Trust are secured by the Property. The lien created by the Deed of Trust was perfected by 

recording of the Deed of Trust in the office of the Clerk of the Circuit Court of Petersburg City, 

Virginia. A copy of the recorded Deed of Trust is attached hereto. 

6. Effective on or about April 1, 2012, the terms of the note and Deed of Trust were 

modified by a written agreement (the "Loan Modification Agreement"). A copy of the Loan 

Modification Agreement is attached hereto. 

7. The legal description of the Property is: 

8. As of October 18, 2019, the outstanding amount of the Obligations due to the 

Movant, less any partial payments or suspense balance is: 

Unpaid Principal Balance $45,312.01

Unpaid, Accrued Interest $1,092.10

Uncollected Late Charges $943.67

Mortgage Insurance Premiums $0.00

Taxes and Insurance Payments on behalf of Debtors $99.92

Other Fees $3,098.00

Other Costs $0.00

Less: Partial Payments $0.00

Minimum Outstanding Obligations $50,545.70

9. The following chart sets forth the number and amount of postpetition payments 

due pursuant to the terms of the Note that have been missed by the Debtor as of October 18, 

2019: 

Number of 

Missed 

Payments 

From To Monthly 

Payment 

Amount 

Total Missed 

Payments

2 09/01/2019 10/01/2019 $552.08 $1,104.16 

Less postpetition partial payments (suspense balance): $-56.05 

Total Postpetition Payments: $1,048.11

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10. In addition to the other amounts due to Movant reflected in this Motion, as of the

date hereof, in connection with seeking the relief requested in this Motion, Movant has also 

incurred $850.00 in legal fees and $181.00 in costs. 

11. The estimated value of the Property is $94,700.00. The basis for such valuation is

Debtors` Schedules. 

12. Cause exists for relief from the automatic stay for the following reasons:

a. Movant's interest in the Property is not adequately protected.

b. Post-petition payments required by the confirmed plan have not been

made to Movant. 

WHEREFORE, Movant prays that this Court issue an Order terminating or modifying 

the stay and granting the following: 

1. Relief from the stay for all purposes allowed by the Note, the Deed of Trust, and

applicable law, including but not limited to allowing Movant (and any successors or assigns) to 

proceed under applicable non-bankruptcy law to enforce its remedies to foreclose upon and 

obtain possession of the Property. 

2. That the 14-day stay described by Bankruptcy Rule 4001(a)(3) be waived.

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

Dated: October 21, 2019 

Respectfully Submitted,

_________________________ 

Andrew Todd Rich VSB# 74296 

Attorney 

BWW Law Group, LLC 

8100 Three Chopt Rd., Suite 240 

Richmond, VA 23229 

(804) 282-0463 (phone)

(804) 282-0541 (facsimile)

bankruptcy@bww-law.com

Attorney for the Movant

/s/ Andrew Todd Rich

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CERTIFICATE OF SERVICE 

I certify that on this 21st day of October, 2019, the following person(s) were or will be 

served with a copy of the foregoing Motion for Relief from Automatic Stay electronically via the 

CM/ECF system or by first class mail, postage prepaid: 

Suzanne E. Wade, Trustee 

7202 Glen Forest Drive 

Ste. 202 

Richmond, VA 23226 

James E. Kane, Esq. 

1313 East Cary Street, P.O. Box 508 

Richmond, VA 23218 

Alonzo Lee Bonner, Sr. 

208 Holly Hill Drive 

Petersburg, VA 23805 

Shirley Harris Bonner 

208 Holly Hill Drive 

Petersburg, VA 23805 

Andrew Todd Rich 

Attorney 

BWW Law Group, LLC 

/s/ Andrew Todd Rich

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