Elizabeth C. Brogan

Counsel for Suzanne E. Wade, Chapter 13 Trustee

Virginia State Bar Number 76539

1313 East Main Street, Suite A

Post Office Box 1780

Richmond, Virginia 23218-1780

(804) 775-0979

UNITED STATES BANKRUPTCY COURT

EASTERN DISTRICT OF VIRGINIA

RICHMOND DIVISION

 In re: Marita Capehart Wilton, Debtor ) Case No. 18-32293-KLP

 ) Chapter 13

OBJECTION TO CONFIRMATION

COMES NOW Elizabeth C. Brogan, Counsel for Suzanne E. Wade, Chapter 13 Trustee, and 

moves this Court to deny confirmation of the Chapter 13 Plan dated April 30, 2018, for the cause as 

follows:

1. The Debtor filed this Chapter 13 Petition, now pending in the United States Bankruptcy 

Court, Eastern District of Virginia, Richmond Division, on April 30, 2018 under 11 U.S.C. 

Chapter 13.

2. This Objection is filed pursuant to 11 U.S.C. § 1325(a)(4).

3. The above-filed Chapter 13 case is not eligible for confirmation due to the Debtor’s failure 

to provide proof of the value of her ownership interest in real property. The Debtor’s 

Schedule A/B discloses her ownership interest in real property located at 2128 Mountain 

View Road, in Powhatan, Virginia, and valued at $137,860.00. Upon information and belief,

the same property is valued at $154,200.00 for tax assessment purposes.

4. The Trustee requests the Debtor provide a comparative market analysis demonstrating the 

value of the above-described property. To the extent the Debtor would suggest the property 

is in need of repairs, the Trustee requests the Debtor provide a professional estimate of the 

cost of such repairs.

WHEREFORE, for the reasons stated herein, the Chapter 13 Trustee, by Counsel, respectfully moves 

the Court to deny confirmation of the Debtor’s proposed Chapter 13 Plan, and for such further and other 

relief as the Court deems necessary.

 Date: June 22, 2018 /s/ Elizabeth C. Brogan . 

 Elizabeth C. Brogan, Counsel for

 Suzanne E. Wade, Chapter 13 Trustee 

Case 18-32293-KLP Doc 14 Filed 06/22/18 Entered 06/22/18 09:41:12 Desc Main

 Document Page 1 of 4
Elizabeth C. Brogan

Counsel for Suzanne E. Wade, Chapter 13 Trustee

Virginia State Bar Number 76539

1313 East Main Street, Suite A

Post Office Box 1780

Richmond, Virginia 23218-1780

(804) 775-0979

CERTIFICATE OF SERVICE

I hereby certify a true copy of the foregoing OBJECTION TO CONFIRMATION was served 

electronically or by first-class mail, postage prepaid, this 22nd day of June, 2018, upon the following 

parties:

Marita Capehart Wilton

2128 Mountain View 

Powhatan, VA 23139

John G. Merna, Counsel for Debtor

The Merna Law Group, P.C. 

3419 Virginia Beach Boulevard, #236 

Virginia Beach, VA 23452 

court@mernalaw.com

Daniel Kevin Eisenhauer, Counsel for Virginia Credit Union, Inc.

Stern & Eisenberg Mid-Atlantic, PC 

9920 Franklin Square Dr, Suite 100 

Baltimore, MD 21236 

bkecf@sterneisenberg.com

 /s/ Elizabeth C. Brogan . 

 Elizabeth C. Brogan, Counsel for

 Suzanne E. Wade, Chapter 13 Trustee 

Case 18-32293-KLP Doc 14 Filed 06/22/18 Entered 06/22/18 09:41:12 Desc Main

 Document Page 2 of 4
Elizabeth C. Brogan

Counsel for Suzanne E. Wade, Chapter 13 Trustee

Virginia State Bar Number 76539

1313 East Main Street, Suite A

Post Office Box 1780

Richmond, Virginia 23218-1780

(804) 775-0979

UNITED STATES BANKRUPTCY COURT

EASTERN DISTRICT OF VIRGINIA

RICHMOND DIVISION

 In re: Marita Capehart Wilton, Debtor ) Case No. 18-32293-KLP

) Chapter 13

 2128 Mountain View )

 Powhatan, VA 23139 )

)

 XXX-XX-5743 )

NOTICE OF OBJECTION TO CONFIRMATION

Elizabeth C. Brogan, Counsel for Suzanne E. Wade, Chapter 13 Trustee, has filed papers with 

the Court objecting to the confirmation of your Chapter 13 Plan dated April 30, 2018.

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 want 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 three (3) days before the date of the hearing, 

you or your attorney must:

_X_ File with the Court, at the address shown below, a written response pursuant to Local 

Bankruptcy Rule 9013-1(H). If you mail your response to the Court for filing, you must 

mail it early enough that the Court will receive it on or before the date stated above.

Clerk of Court

United States Bankruptcy Court

701 East Broad Street, Suite 4000

Richmond, Virginia 23219

You must also mail a copy to:

Elizabeth C. Brogan

Counsel for Suzanne E. Wade, Chapter 13 Trustee

Post Office Box 1780

Richmond, Virginia 23218-1780

_X_ Attend the hearing on the Objection, scheduled to be held on July 18, 2018 at 9:10 

a.m. at United States Bankruptcy Court, 701 East Broad Street, Room 5100, 

Richmond, VA 23219.

Case 18-32293-KLP Doc 14 Filed 06/22/18 Entered 06/22/18 09:41:12 Desc Main

 Document Page 3 of 4
Elizabeth C. Brogan

Counsel for Suzanne E. Wade, Chapter 13 Trustee

Virginia State Bar Number 76539

1313 East Main Street, Suite A

Post Office Box 1780

Richmond, Virginia 23218-1780

(804) 775-0979

If you or your attorney do not take these steps, the Court may decide that you do not oppose the 

relief sought in the Objection, and may enter an order granting that relief.

Date: June 22, 2018 /s/ Elizabeth C. Brogan . 

 Elizabeth C. Brogan, Counsel for

 Suzanne E. Wade, Chapter 13 Trustee

CERTIFICATE OF SERVICE

I hereby certify a true copy of the foregoing NOTICE OF OBJECTION TO CONFIRMATION

was served electronically or by first-class mail, postage prepaid, this 22nd day of June, 2018, upon the 

following parties:

Marita Capehart Wilton

2128 Mountain View 

Powhatan, VA 23139

John G. Merna, Counsel for Debtor

The Merna Law Group, P.C. 

3419 Virginia Beach Boulevard, #236 

Virginia Beach, VA 23452 

court@mernalaw.com

Daniel Kevin Eisenhauer, Counsel for Virginia Credit Union, Inc.

Stern & Eisenberg Mid-Atlantic, PC 

9920 Franklin Square Dr, Suite 100 

Baltimore, MD 21236 

bkecf@sterneisenberg.com 

 /s/ Elizabeth C. Brogan . 

 Elizabeth C. Brogan, Counsel for

 Suzanne E. Wade, Chapter 13 Trustee 

Case 18-32293-KLP Doc 14 Filed 06/22/18 Entered 06/22/18 09:41:12 Desc Main

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