James E. Kane (VSB #30081) 

KANE & PAPA, P.C. 

1313 East Cary Street 

Richmond, VA 23219 

(804) 225-9500 (phone) 

(804) 225-9598 (fax) 

Counsel for Debtor 

IN THE UNITED STATES BANKRUPTCY COURT 

FOR THE EASTERN DISTRICT OF VIRGINIA 

Richmond Division 

 

IN RE: ) 

 ) 

JOSEPH DENVER LAWRENCE ) Case No. 19-35789-KRH 

 ) Chapter 13 

 Debtor ) 

MOTION TO EXPEDITE HEARING ON MOTION 

TO SELL REAL ESTATE AND TO SHORTEN NOTICE PERIOD 

 COME NOW the Debtor, by counsel, and move this Court to Expedite the Hearing on the 

Motion to Sell Real Estate and to Shorten Notice Period, and in support thereof states as follows: 

 1. The Debtor filed this case under Chapter 13 of the U.S. Bankruptcy Code on 

November 1, 2019. 

 2. LoanCare LLC is a secured creditor which holds a first mortgage on the property 

known as 5206 Futura Ave, Henrico, VA 23231, more particularly described as 

ALL THAT CERTAIN LOTS, PIECES OR PARCELS OF LAND, WITH ALL 

IMPROVEMENTS THEREON, KNOWN AS 5206 FUTURA AVENUE, 

FORMERLY CARLTON AVENUE, LYING AND BEING IN THE COUNTY 

OF HENRICO, VIRGINIA KNOWN AND DESIGNATED AS LOTS 4,5,6, 

AND 7, BLOCK B ON THE PALN OF OVER HILL PARK, ALL AS IS 

SHOWN ON A PLAT OF SURVEY MADE BY RALEIGH E. PHELPS, CLS, 

DATED AUGUST 25, 1983. WHICH SAID PLAT OF SURVEY IS 

ATTACHED TO DEED RECORDED IN DEED BOOK 1889, PAGE 451, 

REFERENCE TO WHICH IS HEREBY MADE FOR A MORE COMPLETE 

DESCRIPTION OF THE PROPERTY. 

 (the “Property”). 

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3. The approximate payoff balance on the note secured by said mortgage is 

$154,000.00. The tax assessed value of the Property is $188,100.00. 

 4. Debtor has entered into a contract (“Contract”) for the sale of the Property to 

Brianna Stein for $230,000.00, which, upon closing of the same, will result in LoanCare LLC 

releasing its deed of trust against the Property. 

 5. The amount of the sale or loan proceeds to be applied to the Debtor’s obligations 

under the confirmed plan is $8,902.00, which will result in full payment of all allowed claims. 

 6. The approximate amount of sales proceeds to be paid to the Debtor is $17,000.00. 

7. On December 15, 2021, or as soon thereafter as may be practicable, Debtor 

intends to the Property in accordance with the terms of the Contract. 

WHEREFORE, the Debtor respectfully requests that the Court expedite the hearing on 

the Motion to Sell Real Estate, Shorten the Notice Period required for said Motion, and grant 

them such other and further relief as is just and proper. 

Dated: December 1, 2021 JOSEPH DENVER LAWRENCE 

 By: /s/ James E. Kane 

 Counsel 

James E. Kane (VSB #30081) 

KANE & PAPA, P.C. 

1313 East Cary Street 

Richmond, VA 23219 

(804) 225-9500 (phone) 

(804) 225-9598 (fax) 

Counsel for Debtor 

 

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CERTIFICATION

 I, James E. Kane, pursuant to Local Rule 9013-1(N), do hereby certify that: 

 

 1. I have carefully examined the matter and concluded that there is a true need for 

an emergency hearing, 

 2. I have not created the emergency through any lack of due diligence. 

 3. I have made a bona fide effort to resolve the matter without hearing. 

By: /s/ James E. Kane__________ 

 James E. Kane 

CERTIFICATE OF SERVICE 

I hereby certify that on December 1, 2021, I will electronically file the foregoing with the 

Clerk of Court using the CM/ECF system, which will then send a notification of such filing 

(NEF) to all parties registered to receive notice thereof and will mail the same by first class mail, 

postage pre-paid, to the parties on the attached list. 

/s/ James E. Kane 

Counsel for Debtor 

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IN THE UNITED STATES BANKRUPTCY COURT 

FOR THE EASTERN DISTRICT OF VIRGINIA 

Richmond Division 

 

IN RE: ) 

 ) 

JOSEPH DENVER LAWRENCE ) Case No. 19-35789-KRH 

 ) Chapter 13 

 Debtor ) 

NOTICE OF MOTION AND HEARING 

 The above Debtor has filed papers with the Court to request an order to Expedite the 

hearing and to Shorten the Notice Period with respect to the Motion to Sell Real Estate. 

 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 grant the relief sought in the motion, or if you want the 

court to consider your views on the motion, then, you or your attorney must: 

 File with the court, at the address shown below, a written request for a hearing [or 

written response pursuant to Local Bankruptcy Rule 9013-1(H)]. If you mail your 

request for a hearing (or 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, to: 

Clerk of Court 

United States Bankruptcy Court 

701 East Broad Street 

Richmond, VA 23219 

You must also mail a copy to: 

James E. Kane, Esquire 

KANE & PAPA, P.C. 

1313 East Cary Street 

Richmond, Virginia 23219 

 Attend a hearing scheduled for December 8, 2021 at 12:00 p.m. at U.S. 

Bankruptcy Court, 701 East Broad Street, Room 5000, Richmond, VA 

23219. If no timely response has been filed opposing the relief requested, the 

court may grant the relief without holding a hearing. 

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 REMOTE HEARING INFORMATION: 

Due to the COVID−19 public health emergency, no in-person hearings are being 

held. 

This hearing will take place remotely through Zoom on the date and time scheduled 

herein. 

To appear at the hearing, you must send, by email, a completed request form (the 

“Zoom Request Form”), which is available on the Court's internet website at 

www.vaeb.courts.gov, on the page titled, “Temporary Emergency Provisions 

Regarding ZoomGov Remote Proceeding Access Information.” Email your 

completed Zoom Request Form to the email address listed for the Judge assigned to 

the case. Following receipt of your Zoom Request Form, Court staff will respond to 

the email address from which the request was submitted with additional information 

on how to participate through Zoom. 

***The email address shall be used only to submit Zoom Request Forms. No other 

matters or requests will be considered by Court staff, and under no circumstances will 

any such matters or requests be brought to the Judge’s attention. Failure to comply 

with these instructions may result in appropriate action, including but not limited to 

the imposition of sanctions. 

*** PLEASE NOTE: You MUST submit the Zoom Request Form no later than 

two (2) business days prior to this hearing. Any documentary evidence the 

parties wish to present at the hearing must be filed with the Court in advance of 

the hearing. 

 If you or your attorney do not take these 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. 

Dated: December 1, 2021 JOSEPH DENVER LAWRENCE 

 By: /s/ James E. Kane 

 Counsel 

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James E. Kane (VSB #30081) 

KANE & PAPA, P.C. 

1313 East Cary Street 

Richmond, VA 23219 

(804) 225-9500 (phone) 

(804) 225-9598 (fax) 

Counsel for Debtor 

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CERTIFICATE OF SERVICE 

I hereby certify that on December 1, 2021, I will electronically file the foregoing with the 

Clerk of Court using the CM/ECF system, which will then send a notification of such filing 

(NEF) to all parties registered to receive notice thereof and will mail the same by first class mail, 

postage pre-paid, to the parties on the attached list. 

/s/ James E. Kane 

Counsel for Debtor 

Case 19-35789-KRH Doc 40 Filed 12/01/21 Entered 12/01/21 16:51:12 Desc Main

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}bk1{Credito AresMatix}bk{

Citibank/The Home Depot

Attn: Recovery/Centralized BK

Po Box 790034

St Louis, MO 63179

Citibank/The Home Depot

Attn: Recovery/Centralized Bankruptcy

Po Box 790034

St Louis, MO 63179

Comcast

5401 Staples Mill Road

Henrico, VA 23228

Grnsky/fifththirdbk

Attn: Bankruptcy Dept

1797 North East Expressway

Atlanta, GA 30329

Henrico Fcu

9401 West Broad Street

Henrico, VA 23294

KRS Holdings

2000 West Club Lane

Richmond, VA 23226

LoanCare LLC

Attn: Consumer Solutions Dept

Po Box 8068

Virginia Beach, VA 23450

Macy's

Attn: Bankruptcy

9111 Duke Boulevard

Mason, OH 45040

Mariner Finance

7445 Lee Davis Road

Suite 106

Mechanicsville, VA 23111

Mariner Finance, LLC

Attn: Bankruptcy

8211 Town Center Drive

Nottingham, MD 21236

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Verizon

P.O. Box 660720

Dallas, TX 75266-0270

Yvette Lawrence

5206 Futura Ave

Henrico, VA 23231

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