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UNITED STATES BANKRUPTCY COURT 

EASTERN DISTRICT OF VIRGINIA 

ALEXANDRIA DIVISION 

In re: 

 

BRIAN THOMAS SAPP, 

 

Debtor. 

Case No. 18-12794-BFK 

Chapter 7 

Adv. Proc. No. 18-01111-BFK 

KRAZROCK GROUP, LLC, 

Petitioner, 

v. 

BRIAN THOMAS SAPP, 

Respondent. 

DECLARATION OF ANDREA CAMPBELL 

DAVISON IN SUPPORT OF ENTRY OF DEFAULT 

I, Andrea Campbell Davison, declare in accordance with 28 U.S.C. § 1746:

1. I am an attorney at the firm of Bean Kinney & Korman, P.C., and am counsel to 

Krazrock Group, LLC (the “Plaintiff”). I submit this declaration in support of the foregoing 

Motion for Entry of Default against Brian Thomas Sapp (the “Defendant”) in the abovecaptioned adversary proceeding. 

2. On August 14, 2018, the Defendant filed a voluntary petition for relief pursuant to 

Chapter 7 of the Bankruptcy Code. 

3. The Plaintiff has timely filed a proof of claim against the Defendant in the amount 

of $1,107,500.00, plus unliquidated interest, costs and damages as detailed in Fairfax County 

Circuit Court Civil Action No. 2018-06584 (the “Claim”). 

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4. On November 13, 2018, the Plaintiff filed a complaint (the “Complaint”) against 

the Defendant seeking a determination that the Claim is not dischargable by the Defendant 

because it is for debt obtained by false pretenses, a false representation and/or actual fraud. See 

11 U.S.C. § 523(a)(2)(A). 

5. The Summons and Complaint in this action were served upon the Defendant by 

regular first class mail, postage pre-paid, on November 14, 2018, in accordance with Fed. R. 

Bankr. Proc. 7004. A copy of the Certificate of Service is attached hereto and incorporated by 

reference as Exhibit A. 

6. The Summons issued by the Court fixed the last date for the Defendant to answer 

or move in response to the Complaint as December 14, 2018. The Defendant has not answered or 

moved in response to the Complaint by the time fixed by the court or by Fed. R. Bankr. Proc. 

7012(a). The Defendant has not sought any extension of time to answer, move or otherwise 

respond to the Complaint. 

7. Upon information and belief, the Defendant is not in military service, and is not a 

minor or an incompetent person. 

I declare under penalty of perjury that the foregoing is true and correct on this 19th day of 

December, 2018 in Arlington, Virginia. 

/s/ Andrea Campbell Davison 

 Andrea Campbell Davison 

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Bankruptcy Case No. 18-12794-BFK

Adversary Proceeding Case No. 18-01111-BFK

CERTIFICATE OF SERVICE

I, Atidrea C. Davison (name), certify that I am, and at all times during the

service of process was, not less than 18 years of age and not a party to the matter concerning which service of process was

made. I further certify that the service of this summons and a copy of the complaint was made

November 14, 2018 (date) by:

Mail Service: Regular, first class United States mail, postage fully pre-paid, addressed to:

Brian Thomas Sapp

505 East Braddock Rd., Apt. 406

Alexandria, VA 22314

Personal Service: By leaving the process with defendant or with an officer or agent of defendant at:

n Residence Service: By leaving the process with the following adult at:

D Certified Mail Service on an Insured Depository Institution: By sending the process by certified mail

addressed to the following officer of the defendant at:

O Publication: The defendant was served as follows; [Describe briefly]

O State Law: The defendant was served pursuant to the laws of the State of

(name of state), as follows: [Describe briefly]

Under penalty of perjury, I declare that the foregoing is true and correct.

U I iH-lliSDate Signature

Print Name

Andrea C. Davison

Business Address

2311 Wilson Blvd, 5th Floor

Ciiv Arlington State VA Zin 22201

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