UNITED STATES BANKRUPTCY COURT 

FOR THE 

EASTERN DISTRICT OF VIRGINIA 

Alexandria Division 

In the Matter of: 

 Chapter 13

CLINT ALLEN DRAPER

 Case No. 18-13346-KHK

 Debtor

OBJECTION TO CONFIRMATION OF MODIFIED PLAN, 

NOTICE OF OBJECTION TO CONFIRMATION OF MODIFIED PLAN 

AND 

NOTICE OF SCHEDULED HEARING ON THIS OBJECTION 

Thomas P. Gorman, Chapter 13 Trustee, has filed this objection to confirmation of 

your Modified Chapter 13 Plan filed January 25, 2019. The cause for this objection is 

as follows: 

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

 Debtor has not made a Plan payment since November, 2018. 

Violation of 11 U.S.C. §1325(a)(3) and 11 U.S.C. §1325(b)(1)(B) - Good 

Faith and Disposable Income. 

 Below median Debtor's prior Plan proposed $36,468.00 in total funding 

and estimated a 31% distribution to unsecured creditors. Trustee 

specifically objected to a $173.00 per month Schedule J deduction for 

an unnecessary storage unit. Debtor has now removed that deduction 

which should have increased his disposable monthly income 

correspondingly, but instead he has manipulated his expense deductions 

and is now proposing lower funding to creditors of $32,803.00 total. 

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: 

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Notice of Objection To Confirmation 

Clint Allen Draper, Case # 18-13346-KHK 

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 March 14, 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: _February 28, 2019______ __/s/Thomas P. Gorman ________

 Thomas P. Gorman 

 Chapter 13 Trustee 

 300 N. Washington Street, #400 

 Alexandria, VA 22314 

 (703) 836-2226 

 VSB 26421 

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Notice of Objection To Confirmation 

Clint Allen Draper, Case # 18-13346-KHK 

CERTIFICATE OF SERVICE 

I hereby certify that I have this 28th day of February, 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. 

Clint Allen Draper 

Chapter 13 Debtor 

2753 Patrick Henry Drive 

Woodbridge, VA 22191 

Robert B. Easterling, Esq 

Attorney for Debtor 

General Washington Exec. Ctr. 

2217 Princess Anne St. Ste. 100-2 

Fredericksburg, VA 22401 

 __/s/ Thomas P. Gorman______ 

 Thomas P. Gorman

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