UNITED STATES BANKRUPTCY COURT 

FOR THE EASTERN DISTRICT OF VIRGINIA

Richmond Division 

IN RE:

MICHAEL ROBERT DICKINSON 

Debtor 

Case No.: 18-34024-KRH 

Chapter: 13 

NOTICE OF FORBEARANCE AGREEMENT DUE TO THE COVID-19 PANDEMIC

Now comes PennyMac Loan Services, LLC (“Creditor”), by and through undersigned 

counsel, and hereby submits this Notice of Forbearance Agreement to the Court regarding the 

Debtor’s request for mortgage payment forbearance based upon a material financial hardship 

caused by the COVID-19 pandemic. 

The Debtor recently requested a forbearance period of three (3) months in which

the Debtor will not tender mortgage payments to Creditor that would come due on the 

mortgage starting 07/01/2021 through 09/01/2021. Creditor, at this time, does not waive

any rights to collect the payments that come due during the forbearance period after 

the forbearance plan ends. Furthermore, Creditor does not waive its rights under other 

applicable non-bankruptcy laws and regulations, including, but not limited to, RESPA, and 

the right to collect any post-petition escrow shortage. During the forbearance period 

Creditor may continue to file notices in compliance with Fed. Rule Bankr. P. 3002.1. 

Because of the uncertainties surrounding how long this pandemic will last, Creditor will 

work with Debtor or Debtor’s counsel to determine when Debtor will be able to resume making 

mortgage payments and when/how the Debtor will cure the delinquency created by the 

___________________________ 

Andrew Todd Rich, VSB# 74296 

8100 Three Chopt Road, Suite 240 

Richmond, VA 23229 

(804) 282-0463(Phone)

Attorney for the Creditor

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BWW#:VA-329516

forbearance period (“forbearance arrears”). Once the forbearance plan ends and the Creditor and 

Debtor or Debtor’s counsel agree on an appropriate repayment or loss mitigation program, 

Creditor will file a notice or an amended/supplemental claim consistent with local practice. 

Creditor does not waive its rights to seek relief from the automatic stay for reasons other 

than non-payment of the Mortgage, including, but not limited to, a lapse in insurance coverage or 

non-payment of property taxes. 

In the event it is not the intent of the Debtor to extend the COVID-19 forbearance period, 

upon receipt of notification from the Debtor or Debtor’s counsel, the forbearance extension will 

be cancelled and this notice will be withdrawn. 

Dated: July 20, 2021 Respectfully Submitted, 

BWW Law Group, LLC

__________________________

Andrew Todd Rich, Esq., VSB# 74296 

Attorney 

BWW Law Group, LLC 

8100 Three Chopt Rd., Suite 240 

Richmond, VA 23229 

(804) 282-0463 (phone)

(804) 282-0541 (facsimile)

bankruptcy@bww-law.com

Attorney for the Movant

/s/ Andrew Todd Rich

Case 18-34024-KRH Doc 63 Filed 07/20/21 Entered 07/20/21 09:24:01 Desc Main

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CERTIFICATE OF SERVICE

I certify that on this 20th day of July, 2021, the following person(s) were or will be served

a copy of the foregoing Notice of Forbearance Agreement via the CM/ECF system or by 

first-class mail, postage prepaid: 

Carl M. Bates, Trustee 

P.O. Box 1819 

Richmond, VA 23218 

Sharon Choi Stuart.Attorney 

8002 Discovery Drive 

Suite 422 

Henrico, VA 23229 

Michael Robert Dickinson 

3717 Patterson Avenue 

Richmond, VA 23221 

__________________________

Andrew Todd Rich, Esq. 

Attorney 

BWW Law Group, LLC 

/s/ Andrew Todd Rich

Case 18-34024-KRH Doc 63 Filed 07/20/21 Entered 07/20/21 09:24:01 Desc Main

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