IN THE UNITED STATES BANKRUPTCY COURT 

FOR THE EASTERN DISTRICT OF VIRGINIA 

Richmond Division 

 

IN RE: ) 

 ) 

VONDA KAY RICHARDSON ) Case No. 18−30438−KLP 

 ) Chapter 13 

 ) Trustee: Suzanne E. Wade 

 Debtor ) 

 

NOTICE OF APPLICATION BY KANE & PAPA, P.C. 

FOR SUPPLEMENTAL COMPENSATION 

Kane & Papa, P.C., counsel for the above debtor has filed a Supplemental Application for 

Allowance of Compensation pursuant to 11 U.S.C. §§ 330(a) and 503(b)(2) and Federal Rules of 

Bankruptcy Procedure 2016. 

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 application, or if you want the court 

to consider your views on the application, then, within fourteen (14) days from the date of this 

Notice you or your attorney must: 

 File with the court, at the address shown below, a written request for a hearing [or 

written response pursuant to Local Bankruptcy Rule 9013-1(H)]. If you mail your 

request for a 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, to: 

Clerk of Court 

United States Bankruptcy Court 

701 East Broad Street, Suite 4000 

Richmond, VA 23219 

You must also mail a copy to: 

James E. Kane, Esquire 

KANE & PAPA, P.C. 

P.O. Box 508 

Richmond, Virginia 23218-0508 

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 Attend the hearing scheduled for January 27, 2021 at 10:00 a.m. at 701 East 

Broad Street, Room 5100, Richmond, VA 23219. If no timely response has 

been filed, the Court may grant the relief sought in the application without a 

hearing. 

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

relief sought in the Application and may enter an Order granting relief sought in the application, 

and may enter an Order granting that relief without a hearing. 

Dated: January 6, 2021 KANE & PAPA P.C.

 

By: /s/ James E. Kane 

James E. Kane (VSB #30081) 

KANE & PAPA, P.C. 

P.O. Box 508 

Richmond, VA 23218-0508 

(804) 225-9500 (phone) 

(804) 225-9598 (fax) 

Counsel for Debtor

CERTIFICATE OF SERVICE 

I certify that on January 6, 2021, I have transmitted a true copy of the foregoing 

document electronically through the court’s CM/ECF system or by mail to the debtor, chapter 13 

trustee, the United States trustee if other than by the electronic means provided for at Local 

Bankruptcy Rule 2002-1, and to all necessary parties as listed on the matrix attached herewith. 

 /s/ James E. Kane 

James E. Kane 

Counsel for Debtor 

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3 

IN THE UNITED STATES BANKRUPTCY COURT 

FOR THE EASTERN DISTRICT OF VIRGINIA 

Richmond Division 

 

IN RE: ) 

 ) 

VONDA KAY RICHARDSON ) Case No. 18−30438−KLP 

 ) Chapter 13 

 ) Trustee: Suzanne E. Wade 

 Debtor ) 

 

APPLICATION BY KANE & PAPA, P.C. 

FOR SUPPLEMENTAL COMPENSATION 

COMES NOW, Kane & Papa P.C., counsel for debtor, and pursuant to 11 U.S.C. 

§§ 330(a), 331(b)(2), and 503(b)(2) and Federal Rules of Bankruptcy Procedure 2016, 

respectfully applies to the Honorable Court for approval and payment of supplemental fees in the 

amount of $1,655.10, which includes attorney fees of $1,645.00 and costs of $10.10. 

1. The period covered by this application is for additional work not included in the initial 

“no-look” fees through the date of this Application. 

2. Fees in the amount of $5,223.00 have either been previously paid by the debtor or 

approved for payment through the Chapter 13 Plan. 

3. James E. Kane was admitted to practice law in 1989 and has been practicing for 31 years. 

The hourly rate charged by James E. Kane is $350.00 per hour for attorney time, and 

$100 per hour for Paralegal time. 

4. Pursuant to Bankruptcy Rule 2016(b), a Disclosure of Compensation of Attorney for 

Debtor(s) has been filed in this case and Notice of Filing of Rule 2016-1 Disclosure of 

Compensation was served on the Debtor and the Standing Trustee pursuant to LBR 2016. 

No objection to the compensation requested in the Disclosure Statement has been filed by 

either the Standing Trustee or the Debtor. 

5. Supplemental Compensation is requested for time and costs related to the following 

services: 

Professional services rendered to the debtor in connection with the preparation and 

filing of an Adversary Proceeding to Determine Validity, Extent and Priority of 

Lien pursuant to 11 U.S.C. § 506(a) filed on October 25, 2020, resulting in a 

judgment in favor of Debtor entered by the Court on November 25, 2020. 

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4 

6. An itemized statement of the charges is attached hereto an incorporated herein. Charges 

have not been included for the preparation and cost for noticing of the fee application and 

any court appearances related to the application. 

7. James E. Kane has reviewed the Debtor’s budget and believes that the Chapter 13 Plan 

provides sufficient reserves or may be extended in time so that payments requested herein 

may be made without prejudice to any creditor. Upon information and belief, payment of 

the requested compensation will not reduce the dividend to unsecured creditors as 

provided in the most recently confirmed Chapter 13 Plan. 

WHEREFORE, Kane & Papa P.C., respectfully requests this Honorable Court to approve 

supplemental fees in the amount of $1,655.10 to be paid through the Chapter 13 plan as an 

administrative expense claim pursuant to 11 U.S.C. 503. 

Respectfully submitted, 

KANE & PAPA P.C.

 

By: /s/ James E. Kane 

James E. Kane (VSB #30081) 

KANE & PAPA, P.C. 

P.O. Box 508 

Richmond, VA 23218-0508 

(804) 225-9500 (phone) 

(804) 225-9598 (fax) 

Counsel for Debtor

CERTIFICATE OF SERVICE 

I certify that on January 6, 2021, I have transmitted a true copy of the foregoing 

document electronically through the Court’s CM/ECF system or by mail to the debtors, chapter 

13 trustee, the United States trustee if other than by the electronic means provided for at Local 

Bankruptcy Rule 2002-1, and to all necessary parties, as listed on the matrix attached herewith. 

 /s/ James E. Kane 

 James E. Kane 

 Counsel for Debtor 

 

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Kane & Papa, P.C.

PO BOX 508

RICHMOND, VA 23218 US

804-225-9500

jkane@kaneandpapa.com

INVOICE

BILL TO

Vonda Richardson

9365 Brighter Tower Court

#1404

Glen Allen, VA 23060

INVOICE # 6317

DATE 01/06/2021

DUE DATE 02/01/2021

TERMS Due on receipt

 

DATE ACTIVITY QTY RATE AMOUNT

10/25/2020 Consulting:Legal

Review property valuation on 9365 

Brighter Tower Court, #1404, Glen Allen, 

VA from tax assessment; review first 

DOT and balance with US Bank; review 

Wilmington Savings DOT and balance

0.90 350.00 315.00

10/25/2020 Consulting:Legal

Prepare Complaint against Wilmington 

Savings and both Trustees on DOT

1.40 350.00 490.00

10/28/2020 Consulting:Legal

Review Summons and mail Summons 

and Complaint to Wilmington Savings 

and Trustees, and file certificate of 

service and file with court

0.80 350.00 280.00

10/28/2020 Postage and Delivery

Postage and Delivery- Certified Mail to 

Wilmington Savings and First Class Mail 

to trustees; copy charges

10.10

11/13/2020 Consulting:Legal

Review Answer filed by Defendants; 

email to Johnie Muncy regarding 

consent order; prepare consent order 

and email to Johnie Muncy; BOP order 

to Court

1.10 350.00 385.00

11/16/2020 Consulting:Legal

Review email from court regarding 

changes to consent order; revise 

consent order and email to Johnie 

Muncy

0.30 350.00 105.00

11/24/2020 Consulting:Legal

Review email from Johnie Muncy 

approving revised consent order and 

BOP to court

0.20 350.00 70.00

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Richardson v. Wilmington Savings Fund Society, FSB, et. al. BALANCE DUE $1,655.10

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 Label Matrix for local noticing SPECIALIZED LOAN SERVICING LLC Specialized Loan Servicing LLC 

 0422-3 6200 S. Quebec Street Specialized Loan Servicing LLC 

 Case 18-30438-KLP Greenwood Village, CO 80111-4720 6200 S. Quebec Street 

 Eastern District of Virginia 6200 S. Quebec Street 

 Richmond Greenwood Village, CO 80111-4720 

 Wed Jan 6 14:10:11 EST 2021 

 U.S. Bank National Association U.S. Bank National Association, as Trustee f UST smg Richmond 

 Robertson, Anschutz & Schneid C/O Shapiro & Brown, LLP Office of the U. S. Trustee 

 6409 Congress Avenue 501 Independence Parkway, Suite 203 701 East Broad St., Suite 4304 

 Suite 100 Chesapeake, VA 23320-5174 Richmond, VA 23219-1849 

 Boca Raton, FL 33487-2853 

 

 United States Bankruptcy Court Advance Financial American Web Loan 

 701 East Broad Street ATTN: Virginia Billing 2128 N. 14th St. Suite 1 #130 

 Richmond, VA 23219-1888 100 Oceanside Drive Ponca City, OK 74601-1831 

 Nashville, TN 37204-2351 

 Cash Net USA Credit One Bank Na Dept Of Ed/Navient 

 175 W. Jackson Blvd. Po Box 98873 Attn: Claims Dept 

 Suite 1000 Las Vegas, NV 89193-8873 P.O. Box 9635 

 Chicago, IL 60604-2863 Wilkes Barr, PA 18773-9635 

 Elastic Henrico Doctors Hospital LVNV Funding, LLC its successors and assigns 

 c/o Republic Bank and Trust Resurgent Capital Services assignee of MHC Receivables, LLC and 

 PO Box 950276 PO Box 1927 FNBM, LLC 

 Louisville, KY 40295-0276 Greenville, SC 29602-1927 Resurgent Capital Services 

 PO Box 10587 

 Greenville, SC 29603-0587 

 Mobiloansllc Mr. Cooper Navient Solutions, LLC on behalf of 

 P.O. Box 1409 Attn: Bankruptcy Department of Education Loan Services 

 Marksville, LA 71351-1409 8950 Cypress Waters Blvd PO BOX 9635 

 Coppell, TX 75019-4620 Wilkes-Barre, PA 18773-9635 

 

 Net Credit Financial OneMain OneMain Financial 

 Po Box 645295 P.O. Box 3251 Attn: Bankruptcy Department 

 Cincinnati, OH 45264-5295 Evansville, IN 47731-3251 601 Nw 2nd St #300 

 Evansville, IN 47708-1013 

 Sage Shiva Finance LLC Specialized Loan Servicing LLC 

 PO Box 240 c/o Glen C. Watson, Attorney 6200 S. Quebec St. 

 Commerce, GA 30529-0004 PO Box 121950 Greenwood Village, Colorado 80111-4720 

 Nashville, TN 37212-1950 

 Specialized Loan Servicing/SLS U.S. Attorney’s Office U.S. Bank National Association 

 Attn: Bankruptcy 919 East Main Street, Suite 1900 Nationstar Mortgage LLC D/B/A Mr.Cooper 

 Po Box 636005 Richmond, VA 23219-4625 Attn: Bankruptcy Dept 

 Littleton, CO 80163-6005 PO Box 619096 

 Dallas TX 75261-9096 

 

 Verizon Wilmington Savings Fund Society,FSB Trustee( James E. Kane 

 by American InfoSource LP as agent c/o Specialized Loan Servicing LLC Kane & Papa, PC 

 4515 N Santa Fe Ave 8742 Lucent Blvd, Suite 300 1313 East Cary Street 

 Oklahoma City, OK 73118-7901 Highlands Ranch, Colorado 80129-2386 P.O. Box 508 

 Richmond, VA 23218-0508 

 

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 John P. Fitzgerald, III Suzanne E. Wade Vonda Kay Richardson 

 Office of the US Trustee - Region 4 -R 341 Dial 877-996-8484 Code 2385911 9365 Brighter Tower Court 

 701 E. Broad Street, Ste. 4304 7202 Glen Forest Drive, Ste. 202 #1404 

 Richmond, VA 23219-1849 Richmond, VA 23226-3770 Glen Allen, VA 23060-3790 

 

 The following recipients may be/have been bypassed for notice due to an undeliverable (u) or duplicate (d) address. 

 (d)Specialized Loan Servicing LLC (d)U.S. Bank National Association End of Label Matrix 

 6200 S. Quebec Street Robertson, Anschutz & Schneid Mailable recipients 32 

 Greenwood Village, CO 80111-4720 6409 Congress Avenue Bypassed recipients 2 

 Suite 100 Total 34 

 Boca Raton, FL 33487-2853 

 

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