UNITED STATES BANKRUPTCY COURT 

FOR THE 

EASTERN DISTRICT OF VIRGINIA

Alexandria Division

In the Matter of:

Chapter 13

PATRICK ROCH

Case No. 18-13759-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 November 20, 2018. The cause for this objection is as 

follows:

Violation of 11 U.S.C. §1325(a)(3) – Good Faith and Violation of 11 U.S.C. 

§1325(b)(1)(B) – Disposable Income: Below median Debtor shows 

$813.23/mo. of Disposable Monthly Income on Schedule I/J, but has proposed 

a 1% Plan with payments of only $540.24/mo. 

Violation of 11 U.S.C. §1325(a)(4) – Liquidation Test. Debtor has 

undervalued his real estate at $360,000.00. Zillow values it at $397,281.00, 

making a 1% Plan inappropriate. 

Violation of 11 U.S.C. §1325(a)(6) – Feasibility. Plan does not provide for 

lease listed on recently filed Schedule G. 

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 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 

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Notice of Objection To Confirmation

Patrick Roch, Case # 18-13759-KHK

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 January 17, 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: _December 14, 2018______ __/s/Thomas P. Gorman ________

Thomas P. Gorman

Chapter 13 Trustee

300 N. Washington Street, #400

Alexandria, VA 22314

(703) 836-2226

VSB 26421

CERTIFICATE OF SERVICE

I hereby certify that I have this 14th day of December, 2018 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.

Patrick Roch

Chapter 13 Debtor

102 Reflection Way

Sterling, VA 20164 

Ashvin Pandurangi

Attorney for Debtor

AP Law Group, PLC. 

7777 Leesburg Pike, Suite 402n

Falls Church, VA 22043 

__/s/ Thomas P. Gorman______

Thomas P. Gorman

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