Susan H. Call, Esquire

Staff Counsel for

Carl M. Bates, Chapter 13 Trustee

P.O. Box 1819

Richmond, VA 23218-1819

(804) 237-6800

VSBN 34367

UNITED STATES BANKRUPTCY COURT

EASTERN DISTRICT OF VIRGINIA

RICHMOND DIVISION

In re: Franklin D. Crum ) Case No: 19-30715

aka Frank D. Crum ) Chapter 13

Randi T. Abinette )

aka Randi Crum )

OBJECTION TO CONFIRMATION

 

COMES NOW, Susan H. Call, Counsel for Carl M. Bates the Chapter 13 Trustee, and moves this Court 

to deny confirmation of the Chapter 13 Plan filed on February 25, 2019, for the cause as follows:

1. The Debtors filed this Chapter 13 Petition on February 11, 2019 under 11 U.S.C. Chapter 13, now 

pending in the United States Bankruptcy Court, Eastern District of Virginia, Richmond Division.

2. This Objection is filed pursuant to 11 U.S.C. 1325 (b) (1) (B).

3. The above filed Chapter 13 Plan fails to provide that all of the debtor’s projected disposable income 

in the applicable commitment period will be applied to the plan payments, shown by:

a. Upon information and belief, the Debtors understate income on Schedule I and 22C. The 

Trustee requests six months of stubs or proof of income from all sources during the six 

month period.

b. The Trustee requests a copy of the Lease to Own real estate, and suggests all liquidation 

requirements be met.

c. The Chapter 13 Trustee would suggest that all required income be paid into the Chapter 13 

Plan. 

WHEREFORE, for the reasons stated herein, the Chapter 13 Trustee, by Counsel, Susan H. Call, 

respectfully moves the Court to deny confirmation of the Debtors’ proposed Chapter 13 Plan as filed with the 

Court, and for such further and other relief as in the premises may seem just.

Date: April 17, 2019 /s/Susan H. Call

Susan H. Call, Counsel for

Carl M. Bates

Chapter 13 Trustee

Case 19-30715-KLP Doc 17 Filed 04/17/19 Entered 04/17/19 16:06:19 Desc Main

 Document Page 1 of 4
Susan H. Call, Esquire

Staff Counsel for

Carl M. Bates, Chapter 13 Trustee

P.O. Box 1819

Richmond, VA 23218-1819

(804) 237-6800

VSBN 34367

Certificate of Service

I hereby certify that on April 17, 2019, I have mailed or hand-delivered a true copy of the foregoing 

Objection to Confirmation to the debtor(s), Franklin D. Crum and Randi T. Abineete, 14409 Woods Walk Ct., 

Midlothian, VA 23112 and electronically sent to debtor’s attorney, Pia J. North, Esquire, help@pianorth.com.

/s/Susan H. Call

Susan H. Call, Counsel for

Carl M. Bates

Chapter 13 Trustee

Case 19-30715-KLP Doc 17 Filed 04/17/19 Entered 04/17/19 16:06:19 Desc Main

 Document Page 2 of 4
Susan H. Call, Esquire

Staff Counsel for

Carl M. Bates, Chapter 13 Trustee

P.O. Box 1819

Richmond, VA 23218-1819

(804) 237-6800

VSBN 34367

UNITED STATES BANKRUPTCY COURT

EASTERN DISTRICT OF VIRGINIA

RICHMOND DIVISION

In re: Franklin D. Crum ) Case No: 19-30715

aka Frank D. Crum ) Chapter 13

Randi T. Abinette )

aka Randi Crum )

Debtor Address 14409 Woods Walk Court

Midlothian, VA 23112

Last four digits of Social Security No(s).: 3392

6288

NOTICE OF OBJECTION TO CONFIRMATION

Susan H. Call, Counsel for Carl M. Bates the Chapter 13 Trustee, has filed papers with the Court 

objecting to confirmation of your Chapter 13 Plan, which was filed in this case.

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 request for a hearing [or a written 

response pursuant to Local Bankruptcy Rule 9013-1(H)]. If you mail your request for hearing (or 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.

Clerk of Court

United States Bankruptcy Court

701 East Broad Street, Suite 4000

Richmond, VA 23219

Case 19-30715-KLP Doc 17 Filed 04/17/19 Entered 04/17/19 16:06:19 Desc Main

 Document Page 3 of 4
Susan H. Call, Esquire

Staff Counsel for

Carl M. Bates, Chapter 13 Trustee

P.O. Box 1819

Richmond, VA 23218-1819

(804) 237-6800

VSBN 34367

You must also mail a copy to:

Susan H. Call, Counsel for 

Carl M. Bates

Chapter 13 Trustee

P.O. Box 1819

Richmond, VA 23218

Attend a hearing to be scheduled at a later date. You will receive separate notice of hearing. If 

no timely response has been filed opposing the relief requested, the court may grant the relief without 

holding a hearing.

 X Attend the hearing on the objection scheduled to be held on April 24, 2019 at 9:10 am at United 

States Bankruptcy Court, 701 East Broad Street, Richmond, VA 23219, Room 5100.

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: April 17, 2019 /s/Susan H. Call

Susan H. Call, Counsel for 

Carl M. Bates

Chapter 13 Trustee

P.O. Box 1819

Richmond, VA 23218-1819

VSBN 34367

Certificate of Service

I hereby certify that on April 17, 2019, I have mailed or hand-delivered a true copy of the foregoing Notice of 

Objection to Confirmation to the debtor(s), Franklin D. Crum and Randi T. Abineete, 14409 Woods Walk Ct., 

Midlothian, VA 23112 and electronically sent to debtor’s attorney, Pia J. North, Esquire, help@pianorth.com.

/s/Susan H. Call

Susan H. Call, Counsel for 

Carl M. Bates

Chapter 13 Trustee

Case 19-30715-KLP Doc 17 Filed 04/17/19 Entered 04/17/19 16:06:19 Desc Main

 Document Page 4 of 4