MARK MEYER

VA BAR 74290 

ROSENBERG & ASSOCIATES, LLC

4340 EAST WEST HIGHWAY

SUITE 600 

BETHESDA, MARYLAND 20814

301-907-8000

IN THE UNITED STATES BANKRUPTCY COURT

FOR THE EASTERN DISTRICT OF VIRGINIA 

Located in Alexandria

IN RE 

Bobbie Upasna Vardan Case No. 17-13848

Chapter 11

 Debtor 

____________________________________________________________________ 

OBJECTION TO CONFIRMATION OF CHAPTER 11 PLAN 

COMES NOW, Wilmington Savings Fund Society, FSB d/b/a Christiana Trust, not 

individually but as trustee for Hilldale Trust, by Counsel, and for its Objection to Confirmation 

of the Chapter 11 Plan filed by the debtor states as follows:

1. The bank is a secured creditor of the debtor pursuant to a Deed of Trust dated

October 1, 2007 which secures a Mortgage Note to real property of the Debtors

located at 855 Nicholas Run Drive, Great Falls, VA 22066.

2. As of the date of filing, the lender was owed approximately $2,457,889.92 of

which $482,226.96 are the pre-petition arrears.

3. The Plan makes no provision for payment of the above pre-petition arrears and

further provides for that the Debtor will make monthly payments of $10,000 for 12

months, $11,000 for the next 12 months and then payments of $14,000. The

current monthly payment amount is $14,167.18.

4. Creditor objects to this as Plan as it fails to comply with 11 U.S.C. Section 1123

for the following reasons:

a) The plan fails to provide for the pre-petition arrearage claim and fails to

cure the default; 

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MARK MEYER

VA BAR 74290 

ROSENBERG & ASSOCIATES, LLC

4340 EAST WEST HIGHWAY

SUITE 600 

BETHESDA, MARYLAND 20814

301-907-8000

b) The plan attempts to modify the rights of the holder of a secured claim

secured by the debtor’s principal residence; 

c) The plan fails to provide adequate means for implementation of the plan.

WHEREFORE, the Movant respectfully requests that Confirmation of the 

Chapter 11 Plan submitted by the Debtors herein be denied, and for any other relief the 

Court deems necessary. 

Respectfully Submitted, 

ROSENBERG & ASSOCIATES, LLC 

 _____________________ 

Mark D. Meyer, #74290 

4340 East West Highway, Suite 600 

Bethesda, Maryland 20814 

(301) 907-8000

/s/ Mark D. Meyer

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IN RE

SANDEEP VARDAN

FDBA CARDIOMED PLLC

BOBBIE UPASNA VARDAN

 Debtor

Case No. 17-13848-KHK

Chapter 11

CERTIFICATE OF SERVICE 

 I hereby certify that on the 25th day of April, 2018, the Objection to Plan 

was mailed, first class mail, postage prepaid, upon the following who were not 

served via CM/ECF: 

IN THE UNITED STATES BANKRUPTCY COURT 

FOR THE EASTERN DISTRICT OF VIRGINIA

 Alexandria Division

Bobbie Vardan

855 Nicholas Run Drive

Great Falls, VA 22066

Sandeep Vardan

fdba CardioMed Pllc

P.O. Box 25

Great Falls, VA 22066

Bobbie Upasna Vardan

855 Nicholas Run Drive

Great Falls, VA 22066

Bobbie Vardan, Esquire

Law Office of Bobbie Vardan, Esq.

PO Box 25, Great Falls VA 22066

(served via CM/ECF) 

Judy A. Robbins, Trustee

Office of US Trustee - Region 4-R

701 E. Broad Street, Suite 4304

Richmond, VA 23219

(served via CM/ECF)

Mark D. Meyer, Esq.

Rosenberg & Associates, LLC

4340 East West Highway, Suite 600

Bethesda, MD 20814

/s/ Mark D. Meyer, Esq.

Respectfully Submitted, 

MARK MEYER

DC BAR 475552

MD BAR 15070

VA BAR 74290

ROSENBERG &

ASSOCIATES, LLC

 4340 East West Highway

SUITE 600

BETHESDA, MD 20814

(301) 907-8000

FILE NUMBER: 66300

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