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: ) 

 ) 

SHANNELL JONES MCCALL ) Case No. 20−31325−KRH 

 ) Chapter 13 

 Debtor ) 

MOTION TO EXPEDITE HEARING ON MOTION 

TO INCUR DEBT AND TO SHORTEN NOTICE PERIOD 

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

Motion to Incur Debt 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 

March 9, 2020. 

 2. The Debtor has applied for and Basic Auto Sales RVA has approved a loan to the 

Debtor in the amount of $21,357.38 plus interest at 16.99% per annum to be repaid with 72 equal 

monthly payments of $475.00 for the purchase of a 2020 Nissan Altima or similar vehicle. 

3. The Debtor needs to purchase the referenced vehicle because her current vehicle 

has broken down, and she needs a replacement vehicle to travel to and from work. 

4. The purchase of the vehicle is in the best interest of the Debtor and will facilitate 

her ability to perform under her Chapter 13 Plan filed herein. 

 5. The Debtor’s Chapter 13 Plan has been confirmed. 

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

their Motion to Incur Debt, Shorten the Notice Period required for said Motion, and grant her 

such other and further relief as is just and proper. 

Dated: December 9, 2020 SHANNELL JONES MCCALL 

 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 

 

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 

Case 20-31325-KRH Doc 21 Filed 12/09/20 Entered 12/09/20 12:04:38 Desc Main

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CERTIFICATE OF SERVICE 

I hereby certify that on December 9, 2020, 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 20-31325-KRH Doc 21 Filed 12/09/20 Entered 12/09/20 12:04:38 Desc Main

Document Page 3 of 7
IN THE UNITED STATES BANKRUPTCY COURT 

FOR THE EASTERN DISTRICT OF VIRGINIA 

Richmond Division 

 

IN RE: ) 

 ) 

SHANNELL JONES MCCALL ) Case No. 20−31325−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 her Motion to Incur Debt. 

 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 16, 2020 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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 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 9, 2020 SHANNELL JONES MCCALL 

 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 

Case 20-31325-KRH Doc 21 Filed 12/09/20 Entered 12/09/20 12:04:38 Desc Main

Document Page 5 of 7
CERTIFICATE OF SERVICE 

I hereby certify that on December 9, 2020, 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 20-31325-KRH Doc 21 Filed 12/09/20 Entered 12/09/20 12:04:38 Desc Main

Document Page 6 of 7
 Label Matrix for local noticing United States Bankruptcy Court Ashton Square Apartments 

 0422-3 701 East Broad Street 603-A Westover Hills Blvd. 

 Case 20-31325-KRH Richmond, VA 23219-1888 Richmond, VA 23225-0000 

 Eastern District of Virginia 

 Richmond 

 Tue Dec 8 16:29:08 EST 2020 

 Cascade Capital Department Stores National Bank Dept. of Treasury - 

 Santander Consumer USA c/o Quantum3 Group LLC Internal Revenue Service 

 1670 Corporate Cir PO Box 657 P. O. Box 7346 

 Petaluma, CA 94954-6946 Kirkland, WA 98083-0657 Philadelphia, PA 19101-7346 

 

 (p)DSNB MACY S IC System, Inc (p)JEFFERSON CAPITAL SYSTEMS LLC 

 CITIBANK Attn: Bankruptcy PO BOX 7999 

 1000 TECHNOLOGY DRIVE MS 777 Po Box 64378 SAINT CLOUD MN 56302-7999 

 O FALLON MO 63368-2222 Saint Paul, MN 55164-0378 

 Peroutka,Miller,Klima &Peters Santander Consumer USA Trexis Insurance 

 8028 Ritchie Highway, Ste 300 Attn: Bankruptcy PO Box 64378 

 Pasadena, MD 21122-1360 601 Penn St Saint Paul, MN 55164-0378 

 Reading, PA 19601-3544 

 Verizon Verizon Wireless Virginia Department of Taxatio 

 by American InfoSource as agent P.O. Box 25505 PO Box 2369 

 4515 N Santa Fe Ave Lehigh Valley, PA 18002-5505 Richmond, VA 23218-2369 

 Oklahoma City, OK 73118-7901 

 Wells Fargo Bank NA Carl M. Bates James E. Kane 

 Attn: Bankruptcy 341 Dial 866-813-0912 Code: 8576180 Kane & Papa, PC 

 1 Home Campus Mac X2303-01a P. O. Box 1819 1313 East Cary Street 

 Des Moines, IA 50328-0001 Richmond, VA 23218-1819 P.O. Box 508 

 Richmond, VA 23218-0508 

 

 John P. Fitzgerald, III Shannell Jones McCall 

 Office of the US Trustee - Region 4 -R 625 Westover Hills Blvd. 

 701 E. Broad Street, Ste. 4304 Apartment G 

 Richmond, VA 23219-1849 Richmond, VA 23225-4582 

 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). 

 Deptartment Store National Bank/Macy’s Jefferson Capital Systems LLC (d)Jefferson Capital Systems, LLC 

 Attn: Bankruptcy Po Box 7999 Attn: Bankruptcy 

 9111 Duke Boulevard Saint Cloud Mn 56302-9617 16 Mcleland Road 

 Mason, OH 45040-0000 Saint Cloud, MN 56303-0000 

 End of Label Matrix 

 Mailable recipients 19 

 Bypassed recipients 0 

 Total 19 

Case 20-31325-KRH Doc 21 Filed 12/09/20 Entered 12/09/20 12:04:38 Desc Main

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