James E. Kane (VSB #30081) 

KANE & PAPA, P.C. 

1313 East Cary Street 

Richmond, VA 23219 

Telephone: (804) 225-9500 

Facsimile: (804) 225-9598 

Email: jkane@kaneandpapa.com 

Counsel for Debtor 

IN THE UNITED STATES BANKRUPTCY COURT 

FOR THE EASTERN DISTRICT OF VIRGINIA 

Richmond Division 

 

IN RE: ) 

 ) 

KEVLEENA SHENESE WEBB ) Case No. 20−30776−KRH 

 ) Chapter 13 

 Debtor ) 

DEBTOR’S RESPONSE TO OBJECTION TO CHAPTER 13 PLAN 

COMES NOW the Debtor, by counsel, and as and for Debtor’s Response to Objection 

(“Objection”) to Plan filed by Afrikka Ennis and LaVaniel Ennis, Jr. (“Ennis”), states as follows: 

1. The allegations contained in Paragraph 1 of the Objection are admitted. 

2. The allegations contained in Paragraphs 2 of the Objection are denied as phrased. 

3. The Debtor is without sufficient information to admit or deny the allegations 

contained in paragraph 3 of the Objection and therefore denies the same. 

4. The allegations contained in Paragraphs 4, 5, and 6 of the Objection are denied 

and the Debtor demands strict proof thereof. 

5. The gravamen of the Objection is that the Debtor filed this case in bad faith. On 

March 4, 2020 the Court conducted a hearing on a Motion to Impose Stay filed by the Debtor, 

which Motion and Notice of Hearing were mailed to the Ennises on February 19, 2020. 

6. At said hearing the Debtor provided testimony under oath concerning the 

circumstances of the filing of this and prior cases. At the conclusion of the hearing the Court 

made a finding that the filing of this case was in good faith as to all creditors and ordered that the 

Case 20-30776-KRH Doc 23 Filed 04/01/20 Entered 04/01/20 11:20:19 Desc Main

Document Page 1 of 3
2 

automatic stay of 11 U.S.C. § 362(a) be imposed and extended without condition as to Debtor, 

her property, all creditors, and property of the bankruptcy estate throughout the pendency of this 

case. 

7. Based on the foregoing, the Ennises are collaterally estopped from re-litigation 

the issue of good faith in the form of their Objection, and the Objection should be overruled. 

8. On March 30, 2020 the Court entered an Order on the Ennises’ Motion for Relief 

from the Automatic Stay that fully addresses and resolves the exact issues contained in the 

Objection, rendering the Objection moot. 

 WHEREFORE, the Debtor respectfully requests that the Objection to Plan filed by the 

Ennises be overruled, and for such other relief as the Court deems appropriate. 

 KEVLEENA SHENESE WEBB 

 

 By: /s/ James E. Kane 

 Counsel 

James E. Kane (VSB #30081) 

KANE & PAPA, P.C. 

1313 East Cary Street 

Richmond, VA 23219 

Telephone: (804) 225-9500 

Facsimile: (804) 225-9598 

Email: jkane@kaneandpapa.com 

Counsel for Debtor 

Case 20-30776-KRH Doc 23 Filed 04/01/20 Entered 04/01/20 11:20:19 Desc Main

Document Page 2 of 3
3 

CERTIFICATE OF SERVICE 

I hereby certify that on April 1, 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 I mailed a copy by first class mail, 

postage pre-paid to: 

Afrikka L. Ennis 

LaVaniel Ennis, Jr. 

8218 Tattertron Trail 

North Chesterfield, VA 23237 

 /s/ James E. Kane 

James E. Kane (VSB #30081) 

KANE & PAPA, P.C. 

1313 East Cary Street 

Richmond, Virginia 23219 

Telephone: (804) 225-9500 

Facsimile: (804) 225-9598 

Email: jkane@kaneandpapa.com 

Case 20-30776-KRH Doc 23 Filed 04/01/20 Entered 04/01/20 11:20:19 Desc Main

Document Page 3 of 3