UNITED STATES BANKRUPTCY COURT

EASTERN DISTRICT OF VIRGINIA

ALEXANDRIA DIVISION

In Re:

JOEL THOMAS RIDENOUR

Debtor CASE NO.: 18-13001-KHK

CHAPTER 13

.

OBJECTION TO CONFIRMATION (CHAPTER 13)

AND NOTICE OF OBJECTION AND HEARING

TO THE HONORABLE JUDGE KLINETTE H. KINDRED:

Ford Motor Credit Company LLC (“Ford”), a secured creditor of the Debtor, by counsel,

respectfully objects to the Debtor’s Chapter 13 plan on the following grounds, to wit:

1. The Debtor filed for relief pursuant to Chapter 13 on September 1, 2018 and

subsequently filed a Chapter 13 Plan (the “Plan”).

2. Thomas P. Gorman was appointed Chapter 13 Trustee.

3. On June 14, 2014, the Debtor entered in a Retail Installment Sale Contract

with Ally to purchase a 2012 Lincoln MKZ, VIN 3LNHL2GC1CR804541 (“Lincoln”). A copy of

the Contract is attached as Exhibit “A”. The Debtor is in default for the payment due on August

18, 2018 in the amount of $446.15.

Carl A. Eason, Esquire

Counsel for Ford

Wolcott Rivers Gates

200 Bendix Road, Suite 300 

Virginia Beach, VA 23452

bankruptcy@wolriv.com

 (757) 497-6633

VSB #18636

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4. On June 14, 2015, the Debtor entered in a Retail Installment Sale Contract with Ally

to purchase a 2013 Ford Focus, VIN 1FADP3F28DL231519 (“Ford Focus”). A copy of Contract

is attached as Exhibit “B”. The Debtor is in default for the payment due on August 29, 2018 in the

amount of $250.00.

5. The Plan does not list the secured claims of Ally with respect to the Ford Focus and

the Lincoln involved herein.

6. Although the Plan does not provide for Ally’s debts, Schedule J proposes for the

Debtor to pay a total of $680.35 for two vehicles which are not identified. 

WHEREFORE, Ford objects to the Chapter 13 plan and moves this Court to deny

confirmation of the same.

FORD MOTOR CREDIT COMPANY LLC 

 

By: /s/ Carl A. Eason 

Of Counsel

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UNITED STATES BANKRUPTCY COURT

EASTERN DISTRICT OF VIRGINIA

ALEXANDRIA DIVISION

In re:

JOEL THOMAS RIDENOUR

(SSN -4070)

Debtor,

CASE NO.: 18-13001-KHK

CHAPTER 13

P.O. Box 22576

Alexandria, VA 22304

NOTICE OF OBJECTION AND HEARING

Ford Motor Credit Company LLC has filed papers with the Court objecting to your 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.)

If you do not want the court to deny confirmation of your plan, or if you want the court to consider

your views on the objection, you or your attorney must:

: Send to the parties listed below at least 14 days written notice of a hearing, which

may be set on any regularly-scheduled objection day of the judge assigned in the

case. If necessary, you may obtain a list of such dates from the court's website at

www.vaeb.uscourts.gov under the link for "Calendars." The original notice must

be filed with the clerk. If you are not represented by an attorney, you may instead

file with the clerk a written request for hearing. If you mail your request for hearing

to the court for filing, you must mail it early enough so the court will receive it on

or before the date stated above. The address of the clerk's office is as follows:

Clerk of Court

United States Bankruptcy Court

200 S. Washington Street

Alexandria, VA 22314

You will be notified by the clerk of the hearing date and will be responsible for

sending notice of hearing to the parties listed below.

: File with the court, at the address shown above, 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/objection as conceded, and issue an order granting the requested relief

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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 also send a copy to the persons listed below.

: Attend the hearing on the Objection scheduled to be held on November 8,

2018 at 9:30 a.m. at United States Bankruptcy Court, 200 South Washington

Street, Judge Kindred’s Courtroom, 3

rd Floor, Courtroom III, Alexandria, VA

22314. If no timely response has been filed opposing the motion/objection, the

court may grant the relief without holding a hearing.

A copy of any written response must be sent to:

Carl A. Eason, Esquire

200 Bendix Road, Suite 300

Virginia Beach, VA 23452

Brian V. Lee, Esquire

1250 Connecticut Ave. NW

Second Floor

Washington, DC 20036

Thomas P. Gorman, Trustee

300 N. Washington Street, Ste. 400

Alexandria, VA 22314

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

objection to confirmation.

Date: September 11, 2018 /s/ Carl A. Eason

Carl A. Eason, Esquire

200 Bendix Road, Suite 300

Virginia Beach, VA 23452

(757) 497-6633

Virginia State Bar No. 18636

Counsel for Ford

CERTIFICATION OF SERVICE

I hereby certify that I have on this 11

th

day of September, 2018, mailed or hand-delivered or

electronically sent a true copy of the foregoing Notice of Objection and Hearing to the parties listed on the

attached service list.

Brian V. Lee, Esquire

Counsel for Debtor

1250 Connecticut Ave. NW

Second Floor

Washington, DC 20036

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Thomas P. Gorman, Trustee

300 N. Washington Street, Ste. 400

Alexandria, VA 22314

Joel Thomas Ridenour

P.O. Box 22576

Alexandria, VA 22304

/s/ Carl A. Eason

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