18-703761

UNITED STATES BANKRUPTCY COURT

FOR THE EASTERN DISTRICT OF VIRGINIA 

Richmond Division

In Re: Tina Cantwell-Brooke Case No. 18-35289 KLP

Chapter 13

NOTICE OF OBJECTION TO DEBTOR’S CHAPTER 13 PLAN AND HEARING 

THEREON

Real Property at 3104 Taylor Avenue, West Point, Virginia 23181 

J.G. Wentworth Home Lending, LLC. (Cenlar FSB, servicer) herein, has filed papers 

with the court objecting to debtor’s chapter 13 plan. 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.) 

The hearing is scheduled for January 2, 2019 at 09:10 a.m. at Judge Phillips' 

Courtroom, 701 East Broad Street, Rm. 5100, Richmond, Virginia 23219.

/s/ Dinh Ngo, Esq.

Dinh Ngo, Esq.

Attorney for Secured Creditor

Bar No. 85661

McCabe, Weisberg & Conway, LLC

312 Marshall Avenue, Suite 800

Laurel, MD 20707

301-490-1196

bankruptcyva@mwc-law.com

CERTIFICATE OF SERVICE

I hereby certify that on the 18th day of December, 2018 I reviewed the Court’s CM/ECF system 

and it reports that an electronic copy of the foregoing pleading will be served electronically by 

the Court’s CM/ECF system on the following:

Case 18-35289-KLP Doc 15 Filed 12/18/18 Entered 12/18/18 11:26:51 Desc Main

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18-703761

Carl M. Bates

P.O. Box 1819

Richmond, Virginia 23218

Matthew Samuel Throop 

Throop Law, P.C. 

530 East Main Street, Ste. 1020 

Richmond, Virginia 23219

I hereby further certify that on the 18th day of December, 2018, a copy of the foregoing pleading 

was also mailed first class mail, postage prepaid to:

Tina Cantwell-Brooke

2410 Landing Rd

Providence Forge, Virginia 23140

(Via U.S Mail)

/s/ Dinh Ngo, Esq.

Dinh Ngo, Esq.

Case 18-35289-KLP Doc 15 Filed 12/18/18 Entered 12/18/18 11:26:51 Desc Main

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18-703761

UNITED STATES BANKRUPTCY COURT

FOR THE EASTERN DISTRICT OF VIRGINIA 

Richmond Division

In Re: Tina Cantwell-Brooke Case No. 18-35289 KLP

Chapter 13

OBJECTION BY SECURED CREDITOR TO PROPOSED PLAN

Comes now the secured creditor, J.G. Wentworth Home Lending, LLC. (Cenlar FSB, 

servicer), which holds a Deed of Trust secured by the Debtor's real property at 3104 Taylor 

Avenue, West Point, Virginia 23181, by and through its attorney, Dinh Ngo, Esq., and objects to 

the proposed plan and to confirmation and for reason therefore states as follows:

1. The Debtor has proposed a plan which includes no provision for payment of 

arrearages owed to J.G. Wentworth Home Lending, LLC. (Cenlar FSB, servicer).

2. The secured creditor J.G. Wentworth Home Lending, LLC. (Cenlar FSB, 

servicer) anticipates filing a Proof of Claim with pre-petition arrearages due in the approximate 

amount of $948.52. 

3. The plan as proposed by the Debtor would therefore be insufficient to pay the 

claim of J.G. Wentworth Home Lending, LLC. (Cenlar FSB, servicer).

Wherefore the Secured Creditor prays this court to enter an Order

1. Denying confirmation of the proposed Chapter 13 Plan, or alternatively 

2. Modifying the Chapter 13 Plan to provide for payment in full of the Claim filed 

by the secured creditor, or alternatively

3. For such other and further relief as the Court deems appropriate.

Respectfully submitted:

/s/ Dinh Ngo, Esq. [dn 12/18/18]

Dinh Ngo, Esq.

Case 18-35289-KLP Doc 15 Filed 12/18/18 Entered 12/18/18 11:26:51 Desc Main

 Document Page 3 of 4
18-703761

Attorney for Secured Creditor

Bar No. 85661

McCabe, Weisberg & Conway, LLC

312 Marshall Avenue, Suite 800

Laurel, MD 20707

301-490-1196

bankruptcyva@mwc-law.com

CERTIFICATE OF SERVICE

I hereby certify that on the 18th day of December, 2018 I reviewed the Court’s CM/ECF system 

and it reports that an electronic copy of the foregoing pleading will be served electronically by 

the Court’s CM/ECF system on the following:

Carl M. Bates

P.O. Box 1819

Richmond, Virginia 23218

Matthew Samuel Throop 

Throop Law, P.C. 

530 East Main Street, Ste. 1020 

Richmond, Virginia 23219

I hereby further certify that on the 18th day of December, 2018, a copy of the foregoing pleading 

was also mailed first class mail, postage prepaid to:

Tina Cantwell-Brooke

2410 Landing Rd

Providence Forge, Virginia 23140

(Via U.S Mail)

/s/ Dinh Ngo, Esq.

Dinh Ngo, Esq.

Case 18-35289-KLP Doc 15 Filed 12/18/18 Entered 12/18/18 11:26:51 Desc Main

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