Aimee T. H. Kessler, VSB #44890

Segan, Mason & Mason, P.C.

7010 Little River Turnpike, #270

Annandale, VA 22003

(703) 354-9170 

Attorney for Creditor

UNITED STATES BANKRUPTCY COURT

EASTERN DISTRICT OF VIRGINIA

Alexandria Division

In re: )

) Case No. 18-10781-KHK

SIAMAK LOGHMANI ) Chapter 13

Debtor. )

OBJECTION TO CONFIRMATION OF PLAN, 

NOTICE OF OBJECTION TO CONFIRMATION OF PLAN, AND

NOTICE OF SCHEDULED HEARING ON THIS MOTION

Heatherbrook Homeowners Association, a secured creditor in part, by counsel, 

has filed this objection to confirmation of your Chapter 13 plan dated March 27, 2018. 

The cause for this is as follows:

1. Creditor’s Proof of Claim was timely filed May 2, 2018, showing a total claim of 

$9,394.46 with $8,936.66 as secured and $457.80 as unsecured.

2. Debtor’s Chapter 13 Plan fails to include Creditor as a secured creditor. Creditor 

should be listed in Paragraph 6 of the Chapter 13 plan as a creditor secured by 

Debtor’s principal residence.

3. Debtor has failed to include the currently accruing assessment installments in his 

proposed budget.

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 motion, 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, at the address shown below, 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 also mail a copy to the persons listed below. 

Case 18-10781-KHK Doc 16 Filed 05/02/18 Entered 05/02/18 11:13:47 Desc Main

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Aimee T. H. Kessler, VSB #44890

Segan, Mason & Mason, P.C.

7010 Little River Turnpike, #270

Annandale, VA 22003

(703) 354-9170 

Attorney for Creditor

Attend the hearing scheduled to be held on May 10, 2018 at 9:30 a.m. in 

Courtroom #II, 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:

Heatherbrook Homeowners Association

c/o Segan, Mason & Mason, P.C.

7010 Little River Tpk., Ste. 270

Annandale, VA 22003

Clerk of the Court

United States Bankruptcy Court

200 South Washington Street

Alexandria, VA 22314

 Thomas P. Gorman, Chapter 13 Trustee

 300 N. Washington Street, Ste. 400

 Alexandria, VA 22314

If you or your attorney do not take these 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 2, 2018 /s/ Aimée T. H. Kessler

Aimée T. H. Kessler, VSB #44890

SEGAN, MASON & MASON, P.C.

7010 Little River Turnpike, Suite 270

Annandale, VA 22003

Telephone: (703) 354-9170

Facsimile: (703) 354-7638

E-mail: akessler@seganmason.com

Counsel for Heatherbrook Homeowners Association

Case 18-10781-KHK Doc 16 Filed 05/02/18 Entered 05/02/18 11:13:47 Desc Main

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Aimee T. H. Kessler, VSB #44890

Segan, Mason & Mason, P.C.

7010 Little River Turnpike, #270

Annandale, VA 22003

(703) 354-9170 

Attorney for Creditor

CERTIFICATE OF SERVICE

I hereby certify that a copy of the foregoing Notice and Objection to Confirmation 

of Chapter 13 Plan and Notice of Scheduled Hearing were sent via electronic noticing to:

Thomas P. Gorman, Chapter 13 Trustee Nathan A. Fisher, Esquire

300 N. Washington Street, Ste. 400 Fisher-Sandler, LLC

Alexandria, VA 22314 3977 Chain Bridge Road, #2

Fairfax, VA 22030

Attorney for Debtor

this 2nd day of May 2018.

 /s/ Aimée T. H. Kessler

Aimée T. H. Kessler 

Case 18-10781-KHK Doc 16 Filed 05/02/18 Entered 05/02/18 11:13:47 Desc Main

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