BWW#:VA-312479

______________________________

Andrew Todd Rich, VSB#74296 

8100 Three Chopt Rd., Suite 240 

Richmond, VA 23229 

(804) 282-0463

Counsel for the Movant

UNITED STATES BANKRUPTCY COURT 

FOR THE EASTERN DISTRICT OF VIRGINIA

Alexandria Division 

IN RE: 

MARK ANTHONY ANDERSON 

 Debtor 

_______________________________ 

NEWREZ LLC D/B/A SHELLPOINT 

MORTGAGE SERVICING 

 Movant 

v. 

MARK ANTHONY ANDERSON 

 Debtor/Respondent 

and 

LATAUNIA ANDERSON 

 Co-Debtor/Co-Respondent 

and 

THOMAS P. GORMAN 

 Trustee/Respondent 

Case No. 19-10888-KHK 

Chapter 13 

______________________________________________________________________________ 

NOTICE OF DEFAULT 

 Upon information provided by NewRez LLC d/b/a Shellpoint Mortgage Servicing (the 

“Movant”), the undersigned counsel, Andrew Todd Rich and BWW Law Group, LLC, hereby files this 

Notice of Default (the “Notice of Default”), and respectfully represents as follows: 

 1. The Movant is the beneficiary under a Deed of Trust executed by Mark Anthony 

Anderson (the “Debtor”) and Lataunia Anderson (the “Co-Debtor”), which encumbers the real property 

known as 1411 Admiral Drive, Woodbridge, VA 22192 (the “Property”). 

 2. A Consent Order Modifying Automatic Stay and Co-Debtor Stay was entered by the 

Court in this case on August 9, 2019 (the “Consent Order”). The Debtor is in default under the terms of 

the Consent Order. The Debtor has failed to make the following payments required by the terms of the 

Consent Order (the “Default”): 

April 1, 2020 Post Petition Payment $1,871.82 

May 1, 2020 Post Petition Payment $1,871.82 

Suspense $-84.54 

 3. Pursuant to the terms of the Consent Order, within fourteen (14) days of the date of this 

Notice of Default, the Debtor or Chapter 13 Trustee (the “Trustee”) must either: (a) cure the Default by 

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tendering to the Movant $3,759.10 (the total amount of the Default, which includes $100.00 for 

attorney's fees associated with the filing of this Notice of Default) in certified funds at the payment 

address listed in paragraph no. 4 below; (b) file an objection stating that no default exists; or (c) file an 

objection with the court stating any other reason why an Order granting relief from the automatic stay 

should not be entered. 

4. Any cure of the Default must include payment of all amounts set forth herein, as well as

payments which have subsequently become due under the terms of the Consent Order and any amounts 

that are due at the time the Default is cured. Acceptance of partial payment by the Movant during the 

14-day cure period shall not constitute a satisfaction or waiver of the Notice of Default. Any cure

payments should be sent to the following address:

NewRez LLC d/b/a Shellpoint Mortgage Servicing 

P.O. Box 10826 

Greenville, SC 29603-0826 

5. If the Debtor or Trustee do not take one of the actions set forth in paragraph no. 3

hereinabove, the Movant may file a certificate with the court stating that the Movant has complied with 

the terms of the Order, and the court may grant relief from the automatic stay without further notice to 

the Debtor. If the automatic stay is terminated, the Property may be sold at foreclosure. 

Respectfully Submitted,

Dated: June 26, 2020 ________________________________ 

Andrew Todd Rich, VSB# 74296 

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

Counsel for the Movant

CERTIFICATE OF SERVICE 

I certify that on this 26th day of June, 2020, the following persons were or will be served a copy

of the foregoing Notice of Default via the CM/ECF system or by first class mail, postage prepaid: 

Thomas P. Gorman, Trustee 

300 N. Washington St. Ste. 400 

Alexandria, VA 22314 

Nathan Andrew Fisher, Esq. 

3977 Chain Bridge Rd, #2 

Fairfax, VA 22030 

/s/ Andrew Todd Rich

Case 19-10888-KHK Doc 64 Filed 06/26/20 Entered 06/26/20 15:50:32 Desc Main

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Mark Anthony Anderson 

1411 Admiral Drive 

Woodbridge, VA 22192 

Lataunia Anderson 

1411 Admiral Drive 

Woodbridge, VA 22192 

Andrew Todd Rich, Esq. 

Attorney 

BWW Law Group, LLC 

/s/ Andrew Todd Rich

Case 19-10888-KHK Doc 64 Filed 06/26/20 Entered 06/26/20 15:50:32 Desc Main

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