Bradley Jones (VSB No. 85095) 

Counsel for the `Trustee

ODIN FELDMAN & PITTLEMAN PC

1775 Wiehle Avenue, Suite 400

Reston, Virginia 20190

Phone: 703-218-2176

Fax: 703-218-2160

Brad.Jones@opflaw.com

UNITED STATES BANKRUPTCY COURT

FOR THE EASTERN DISTRICT OF VIRGINIA

Alexandria Division

In re: )

)

WILLIAM ANTHONY NECE and ) Case No. 20-10500-BFK

STANETTE LEE NECE, ) Chapter 7

)

Debtors. )

)

LOANCARE, LLC, )

)

Movant, )

)

v. )

)

WILLIAM ANTHONY NECE, )

)

STANETTE LEE NECE, )

)

and )

)

DONALD F. KING, TRUSTEE )

)

Respondents. )

ANSWER

DONALD F. KING, TRUSTEE (the “Trustee”), by counsel, files his Answer to the 

Motion for Relief From the Automatic Stay (the “Motion”) filed by LoanCare, LLC

(“Movant”) in the above referenced case for the property located at 7125 Whetstone 

Road, Alexandria, VA 22306 (the “Property”), and states as follows:

1. The Trustee admits the allegations contained in Paragraphs 1 and 3 of 

the Motion. 

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2. The Trustee, lacking sufficient knowledge of the allegations contained in 

Paragraphs 2 and 4 of the Motion, neither admits nor denies such allegations and 

requires proof thereof. 

3. The Trustee denies the allegations contained in Paragraph 5 of the 

Motion.

AFFIRMATIVE DEFENSE

Assuming, without admitting, that Movant’s allegations in the Motion are 

correct, there is a significant equity cushion protecting Movant’s alleged interest in the 

Property. According to the Debtors’ Schedules, LoanCare, LLC is the first lien holder. 

Dkt. No. 1 at 20. Movant alleges that the total amount due under its Note, including 

interest and attorney’s fees, is $250,741.84 as of April 1, 2020. Dkt. No. 17 at 5. The 

Trustee is having the Property evaluated by a realtor and has received a desktop 

valuation, estimating the value of the Property to be $550,000.00. As a result, there 

appears to be significant equity in the Property. The Trustee is currently investigating 

the Property to determine if this asset can be administered for the benefit of creditors. 

If the Property is sold, the Movant’s debt will be paid in full from any sale of the 

Property by the Trustee or on terms that are agreeable to the Movant. As a result, the 

Trustee believes that Movant’s alleged interests are adequately protected by the equity 

cushion in the Property. 

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WHEREFORE, Donald F. King, Trustee, by counsel, requests that this Court 

enter an order denying Movant’s Motion for Relief from the Automatic Stay. 

DONALD F. KING, TRUSTEE

By Counsel

By: /s/ Bradley D. Jones

Bradley D. Jones (VSB No. 85095)

Counsel for Trustee

ODIN FELDMAN & PITTLEMAN PC

1775 Wiehle Avenue, Suite 400

Reston, Virginia 20190

Phone: 703-218-2176

Fax: 703-218-2160

Brad.Jones@ofplaw.com 

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CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a true and accurate copy of the Answer was sent via 

Notice of Electronic Filing upon counsel for Movant, counsel for Debtor, and all 

registered users in this case pursuant to this Court’s CM/ECF policy.

/s/ Bradley Jones

Bradley Jones

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