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: ) 

 ) 

STEPHANIE DENISE FARRAR ) Case No. 19−36098−KRH 

) Chapter 13 

 Debtor ) 

MOTION TO APPROVE LOAN MODIFICATION 

 COMES NOW, the Debtor, by counsel, and as and for Debtor’s Motion to Approve Loan 

Modification, states as follows: 

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

November 19, 2019. 

 2. Wells Fargo Home Mortgage (“Wells Fargo”) is a secured creditor of the Debtor 

which holds a promissory note from the Debtor (“Note”) secured by a first deed of trust on the 

Debtor’s real property at 20019 Roosevelt Avenue, South Chesterfield, VA 23834, and further 

described as follows (the “Property”): 

ALL that certain lot, piece or parcel of land, with all improvements thereon and 

appurtenances thereto belonging, lying and being in Matoaca District, 

Chesterfield County, Virginia, and known, numbered and designated on a plat 

showing subdivision of West Chesterfield Heights, made by J. W. Pugh, C.E., and 

duly recorded in the Clerk's Office of the Circuit Court of Chesterfield County, 

Virginia, in Plat Book 8, at page 49, as Lot Fifteen (15), in Block "J", reference to 

which plat is hereby made. 

 3. The Debtor has applied for and Wells Fargo has approved a modification of the 

Note reducing the Debtor’s monthly payment of principal, interest, and escrow on the Note from 

$1,261.77 to $1,064.33, decreasing the annual interest rate from 3.75% to 2.8750%, increasing 

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the unpaid principal balance from $162,340.43 to $170,899.00, extending the maturity date from 

February 1, 2039 to July 1, 2051, including a HUD Partial Claim of $9,928.80. A Summary of 

Proposed Loan Modification is attached hereto and a copy of the Loan Modification is attached 

hereto as Exhibit A and is incorporated herein by this reference. 

4. The forgoing modification is in the best interest of the Debtor and will facilitate 

the Debtor’s ability to perform under the Chapter 13 Plan filed herein. 

WHEREFORE, the Debtor requests that the Court enter an Order approving the 

modification of the terms of the Note as stated herein and for such other relief as the Court may 

deem appropriate. 

 STEPHANIE DENISE FARRAR 

 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 

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CERTIFICATE OF SERVICE 

I hereby certify that on October 11, 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 counsel of record who have signed up to receive such notification 

and by first class mail to all parties on the attached list. 

 /s/ James E. Kane 

 James E. Kane 

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IN THE UNITED STATES BANKRUPTCY COURT 

FOR THE EASTERN DISTRICT OF VIRGINIA 

Richmond Division 

 

IN RE: ) 

 ) 

STEPHANIE DENISE FARRAR ) Case No. 19−36098−KRH 

) Chapter 13 

 Debtor ) 

NOTICE OF MOTION AND HEARING 

 The above Debtor has filed Motion to Approve Loan Modification in the above matter. 

 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, within twenty-one (21) days from the date of 

this Notice 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 November 17, 2021 at 12:00 PM at United 

States 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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 REMOTE HEARING INFORMATION: 

Due to the COVID−19 public health emergency, no in-person hearings are being 

held. 

This hearing will take place remotely through Zoom on the date and time scheduled 

herein. 

To appear at the hearing, you must send, by email, a completed request form (the 

“Zoom Request Form”), which is available on the Court's internet website at 

www.vaeb.courts.gov, on the page titled, “Temporary Emergency Provisions 

Regarding ZoomGov Remote Proceeding Access Information.” Email your 

completed Zoom Request Form to the email address listed for the Judge assigned to 

the case. Following receipt of your Zoom Request Form, Court staff will respond to 

the email address from which the request was submitted with additional information 

on how to participate through Zoom. 

***The email address shall be used only to submit Zoom Request Forms. No other 

matters or requests will be considered by Court staff, and under no circumstances will 

any such matters or requests be brought to the Judge’s attention. Failure to comply 

with these instructions may result in appropriate action, including but not limited to 

the imposition of sanctions. 

*** PLEASE NOTE: You MUST submit the Zoom Request Form no later than 

two (2) business days prior to this hearing. Any documentary evidence the 

parties wish to present at the hearing must be filed with the Court in advance of 

the 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. 

Dated: October 11, 2021 

 STEPHANIE DENISE FARRAR 

 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 

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CERTIFICATE OF SERVICE 

I hereby certify that on October 11, 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 counsel of record who have signed up to receive such notification 

and by first class mail to all parties on the attached list. 

 /s/ James E. Kane 

 James E. Kane 

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IN THE UNITED STATES BANKRUPTCY COURT 

FOR THE EASTERN DISTRICT OF VIRGINIA 

Richmond Division 

 

IN RE: ) 

 ) 

STEPHANIE DENISE FARRAR ) Case No. 19−36098−KRH 

) Chapter 13 

 Debtor ) 

Summary of Proposed Loan Modification 

 Original Loan Modified Loan 

Principal Amount $162,340.43 $170,899.00 

Interest Rate 3.75% 2.8750% 

Term or Maturity Date February 1, 2039 July 1, 2051 

Monthly Payment $1,261.77 $1,064.33 

X_ 1. The Modified loan includes future payment changes or balloon payments. The 

terms of any such payment changes or balloon payments are: $9,928.00 under a HUD 

partial claim. 

__ 2. The modification results in a higher monthly payment. The source of the funds 

used to make that payment are: _ 

_X_ 3. The modification results in a lower monthly payment. Choose one of the 

following: 

___ a. The amount of future plan payments will be increased. 

_X_b. The amount of future plan payments will not be increased. 

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}bk1{Credito AresMatix}bk{

Allied Cash Advance

3822 Jefferson Davis Highway

Fredericksburg, VA 22408

Ascendium Education Solutions

PO Box 8961

Madison, WI 53708

Boleman Law Firm

2104 W Laburnum Ave Suite 201

Richmond, VA 23227

Capital One Auto Finance

PO Box 259407

Plano, TX 75025

Check City

2729 B West Broad Street

Richmond, VA 23220

Chesterfield County Treasurer

P.O. Box 70

Chesterfield, VA 23832-0906

Comcast Cable

C/o Credit Management

PO Box 118288

Carrollton, TX 75011

Credit One Bank

P.O. Box 98873

Las Vegas, NV 89193

Fast Auto Loans

6150 Midlothian Turnpike

Richmond, VA 23225

Fort Lee Federal Credit Union

3510 A Avenue

Fort Lee, VA 23801

Jefferson Capital Systems

c/o FNCB

610 Waltham Way

McCarren, NV 89434

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Peoples Advantage FCU

PO Box 3180

Petersburg, VA 23805

Pra Receivables Management LLC

P. O. Box 12914

Norfolk, VA 23541

US Department of Education

PO Box 105028

National Payment Center

Atlanta, GA 30348-5028

Wells Fargo Home Mortgage

PO Box 10335

Des Moines, IA 50306

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