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: )

)

DOROTHY GREGORY COOKE ) Case No. 19−35184−KLP

) Chapter 13

Debtor )

MOTION TO SELL REAL ESTATE 

COMES NOW, the Debtor, by counsel, and as and for Debtor’s Motion to Sell Real 

Estate, states as follows:

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

October 2, 2019.

2. The Debtor and her son, Darnell Johnson, Jr. inherited the property known as

3215 Dorithian Road, Baltimore, MD 21215-7501, more particularly known as 

BEING THE FIRST LOT IN A LEASE DATED NOVEMBER 18, 1948, 

RECORDED AMONG THE LAND RECORDS OF BALTIMORE CITY IN 

LIBER MLP 7636, FOLIO 377, FROM HENRY I. ADLER AND WIFE TO THE 

BEDFORD HOLDING COMPANY, IN WHICH THE PROPERTY WAS 

LEASED FOR THE ANNUAL GROUND RENT OF $108.00, PAYABLE ON 

THE 18TH DAYS OF MAY AND NOVEMBER. THE GROUND RENT WAS 

ACQUIRED BY THE PARTY OF THE FIRST PART BY DEED DATED 

JANUARY 9, 1992, RECORDED AMONG SAID LAND RECORDS IN LIBER 

SEB 3077, FOLIO 327, FROM JULIUS LEVIN TO REUBEN FISHKIND AND 

MINDY FISHKIND, TRUSTEES FOR SCOTT JEREMY FISHKIND. MINDY 

FISHKIND IS THE SURVIVING TRUSTEE OF SAID TRUST. THE 

LEASEHOLD INTEREST WAS ACQUIRED BY DEED DATED JANUARY 

21, 2006, RECORDED IN LIBER FMC 7628, FOLIO 688, FROM HAROLD 

FRANKLIN GREGORY AND ANN C. GREGORY TO THE GRANTEE(S) 

HEREIN.

Case 19-35184-KLP Doc 44 Filed 03/03/21 Entered 03/03/21 18:13:12 Desc Main

Document Page 1 of 7
2

(the “Property”).

3. The property is owned outright with no liens or encumbrances. The appraised

value of the Property is $58,000.00.

4. Debtor and co-owner have entered into a contract (“Contract”) for the sale of the 

Property for $58,000.00. A copy of said contract is attached hereto collectively as Exhibit “A” 

and incorporated herein by this reference.

5. Proceeds from the sale will be split fifty-fifty between Debtor and co-owner.

6. The amount of the sale to be applied to the debtor’s obligations under the 

confirmed plan is $14,000.00, which will not result in full payment of all allowed claims.

7. The approximate amount of sales proceeds to be paid to the Debtor is $15,000.00. 

8. The Debtor is requesting $15,000.00 from her portion of the sales proceeds to 

purchase a vehicle, as she does not currently have a vehicle and has been asking friends and 

family for rides.

9. On March 20, 2021, or as soon thereafter as may be practicable, Debtor intends to 

sell her home interest in the Property in accordance with the terms of the contract.

WHEREFORE, the Debtor requests that the Court enter an Order authorizing the sale of 

the Property in accordance with the terms of the Contract and for such other relief as the Court 

may deem appropriate

Dated: March 3, 2021 DOROTHY GREGORY COOKE

By: /s/ James E. Kane

Counsel

Case 19-35184-KLP Doc 44 Filed 03/03/21 Entered 03/03/21 18:13:12 Desc Main

Document Page 2 of 7
3

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

CERTIFICATE OF SERVICE 

I hereby certify that on March 3, 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 I mailed a true and exact copy to the 

parties on the list attached hereto.

/s/ James E. Kane

Counsel for Debtor

Case 19-35184-KLP Doc 44 Filed 03/03/21 Entered 03/03/21 18:13:12 Desc Main

Document Page 3 of 7
4 

IN THE UNITED STATES BANKRUPTCY COURT

FOR THE EASTERN DISTRICT OF VIRGINIA

Richmond Division

IN RE: ) 

) 

DOROTHY GREGORY COOKE ) Case No. 19−35184−KLP

) Chapter 13 

Debtor ) 

NOTICE OF MOTION AND HEARING

The above Debtor has filed a Motion to Sell Real Estate with the Court. 

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 March 24, 2021 at 10:00 a.m. at U.S.

Bankruptcy Court, 701 East Broad Street, Room 5100, Richmond, VA

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

court may grant the relief without holding a 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.

Case 19-35184-KLP Doc 44 Filed 03/03/21 Entered 03/03/21 18:13:12 Desc Main

Document Page 4 of 7
5

Dated: March 3, 2021 DOROTHY GREGORY COOKE

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

CERTIFICATE OF SERVICE 

I hereby certify that on March 3, 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 I mailed a true and exact copy to the 

parties on the list attached hereto.

/s/ James E. Kane 

Counsel for Debtor

Case 19-35184-KLP Doc 44 Filed 03/03/21 Entered 03/03/21 18:13:12 Desc Main

Document Page 5 of 7
 Label Matrix for local noticing Toyota Motor Credit Corporation United States Bankruptcy Court 

 0422-3 c/o Becket and Lee LLP 701 East Broad Street 

 Case 19-35184-KLP PO Box 3002 Richmond, VA 23219-1888 

 Eastern District of Virginia Malvern, PA 19355-0702 

 Richmond 

 Wed Mar 3 18:08:31 EST 2021 

 Ally Bank Ally Financial Ashley Funding Services, LLC 

 PO Box 130424 Attn: Bankruptcy Dept Resurgent Capital Services 

 Roseville MN 55113-0004 Po Box 380901 PO Box 10587 

 Bloomington, MN 55438-0901 Greenville, SC 29603-0587 

 

 Bank of America, N.A. Bayview Financial Loan Capital One 

 P O Box 982284 Attn: Bankruptcy Dept Attn: Bankruptcy 

 El Paso, TX 79998-2284 4425 Ponce De Leon Blvd. 5th Floor Po Box 30285 

 Coral Gables, FL 33146-1873 Salt Lake City, UT 84130-0285 

 Capital One Bank (USA), N.A. Community Loan Servicing, LLC Gerald Taylor 

 by American InfoSource as agent 4425 Ponce De Leon Blvd., 5th Floor 8500 Perrymont Road 

 4515 N Santa Fe Ave Coral Gable, FL 33146-1873 Richmond, VA 23237-2817 

 Oklahoma City, OK 73118-7901 

 NetCredit Samuel I. White Todd M. Ritter, Esquire 

 175 W. Jackson Blvd., Suite 1000 5040 Corporate Woods Dr. 11901 Iron Bridge Road 

 Chicago, IL 60604-2863 Suite 120 Chester, VA 23831-1458 

 Virginia Beach, VA 23462-4377 

 (p)TOYOTA MOTOR CREDIT CORPORATION Verizon Verizon Wireless 

 PO BOX 8026 by American InfoSource as agent Attn: Bankruptcy 

 CEDAR RAPIDS IA 52408-8026 4515 N Santa Fe Ave 500 Technology Dr, Ste 550 

 Oklahoma City, OK 73118-7901 Weldon Spring, MO 63304-2225 

 Wells Fargo Dealer Services Carl M. Bates Dorothy Gregory Cooke 

 Attn: Bankruptcy 341 Dial 866-813-0912 Code: 8576180 13330 Master Stag Drive 

 Po Box 19657 P. O. Box 1819 Midlothian, VA 23112-1970 

 Irvine, CA 92623-9657 Richmond, VA 23218-1819 

 James E. Kane John P. Fitzgerald, III 

 Kane & Papa, PC Office of the US Trustee - Region 4 -R 

 1313 East Cary Street 701 E. Broad Street, Ste. 4304 

 P.O. Box 508 Richmond, VA 23219-1849 

 Richmond, VA 23218-0508 

 

 The preferred mailing address (p) above has been substituted for the following entity/entities as so specified 

 by said entity/entities in a Notice of Address filed pursuant to 11 U.S.C. 342(f) and Fed.R.Bank.P. 2002 (g)(4). 

 Toyota Financial Services 

 Atty: Bankruptcy Dept 

 Po Box 8026 

 Cedar Rapids, IA 52409-0000 

Case 19-35184-KLP Doc 44 Filed 03/03/21 Entered 03/03/21 18:13:12 Desc Main

Document Page 6 of 7
 

 The following recipients may be/have been bypassed for notice due to an undeliverable (u) or duplicate (d) address. 

 (u)Bayview Loan Servicing LLC (u)Community Loan Servicing, LLC (u)Community Loan Servicing, LLC f/k/a Bayvie

 (d)Toyota Motor Credit Corporation End of Label Matrix 

 c/o Becket and Lee LLP Mailable recipients 22 

 PO Box 3002 Bypassed recipients 4 

 Malvern PA 19355-0702 Total 26 

Case 19-35184-KLP Doc 44 Filed 03/03/21 Entered 03/03/21 18:13:12 Desc Main

Document Page 7 of 7