UNITED STATES BANKRUPTCY COURT 

FOR THE 

EASTERN DISTRICT OF VIRGINIA

Alexandria Division

In the Matter of:

Chapter 13

CAROL BEATSON

Case No. 19-11359-KHK

Debtor

OBJECTION TO CONFIRMATION OF PLAN,

NOTICE OF OBJECTION TO CONFIRMATION OF PLAN

AND

NOTICE OF SCHEDULED HEARING ON THIS OBJECTION

Thomas P. Gorman, Chapter 13 Trustee, has filed this objection to confirmation of 

your Chapter 13 Plan filed May 8, 2019. The cause for this objection is as follows:

Violation of 11 U.S.C. §1325(a)(6) – Feasibility: 

1. Step payments from $200.00/mo. to $450.00/mo. in month 19 and 

then $450.00/mo. to $795.00/mo. in month 37 are highly unrealistic. 

2. 100% Plan is underfunded as follows: 

PERFORMANCE Amount of Plan Payment 200.00 x 18

450.00 x 18

795.00 x 24

Number of Months 60

Total Receipts 30,780.00

Disbursements Required

Trustee 3,162.20 10.00%

Attorney 2,500.00

Taxes/Other Priority 0.00

Secured 23,000.00

Unsecured 6,122.00

Other

Total Disbursements 34,784.20

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.)

Case 19-11359-KHK Doc 18 Filed 06/21/19 Entered 06/21/19 10:56:59 Desc Main

 Document Page 1 of 3
Notice of Objection To Confirmation

Carol Beatson, Case # 19-11359-KHK

If you do not wish 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 five business 

days prior to the hearing date, you or your attorney must:

File with the court a written response with supporting memorandum as required 

by Local Bankruptcy Rule 9013-1(H). Unless a written response and 

supporting memorandum are filed and served by the date specified, the Court 

may deem any opposition waived, treat the motion as conceded, and issue an 

order granting the requested relief without further notice or hearing. If you mail 

your 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. You must mail a copy to the 

persons listed below.

Attend the hearing to be held on July 18, 2019 at 9:30 a.m., in Courtroom III 

on the 3rd floor, United States Bankruptcy Court, 200 South Washington 

Street, Alexandria, VA 22314. If no timely response has been filed opposing 

the relief requested, the court may grant the relief without holding a hearing.

A copy of any written response must be mailed to the following persons:

Thomas P. Gorman

300 North Washington Street, Ste, 400

Alexandria, VA 22314

Clerk of the Court

United States Bankruptcy Court

200 South Washington Street

Alexandria, VA 22314

If you or your attorney do not take steps, the court may decide that you do not 

oppose the relief sought in the motion or objection and may enter an order granting that 

relief.

Date: _June 21, 2019______ __/s/Thomas P. Gorman ________

Thomas P. Gorman

Chapter 13 Trustee

300 N. Washington Street, #400

Alexandria, VA 22314

(703) 836-2226

VSB 26421

Case 19-11359-KHK Doc 18 Filed 06/21/19 Entered 06/21/19 10:56:59 Desc Main

 Document Page 2 of 3
Notice of Objection To Confirmation

Carol Beatson, Case # 19-11359-KHK

CERTIFICATE OF SERVICE

I hereby certify that I have this 21st day of June, 2019, served via ECF to authorized 

users or mailed a true copy of the foregoing Objection to Confirmation, Notice of 

Objection and Notice of Hearing to the following parties.

Carol Beatson

Chapter 13 Debtor

1663 Parkcrest Circle

#101

Reston, VA 20190 

Nathan Fisher, Esq.

Attorney for Debtor

Fisher-Sandler, LLC. 

3977 Chain Bridge Rd. #2

Fairfax, VA 22030 

__/s/ Thomas P. Gorman______

Thomas P. Gorman

Case 19-11359-KHK Doc 18 Filed 06/21/19 Entered 06/21/19 10:56:59 Desc Main

 Document Page 3 of 3