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: ) 

 ) 

NICOLE DONNETTE STEELEY ) Case No. 19-34628-KRH 

 ) Chapter 13 

 Debtor ) 

MOTION TO EXPEDITE HEARING ON MOTION 

TO INCUR DEBT AND TO SHORTEN NOTICE PERIOD 

 COMES NOW the Debtor, by counsel, and moves 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 

September 05, 2019. 

 2. The Debtor has applied for and Movement Mortgage, LLC. has approved a loan 

to the Debtor in the amount of $311,258.00 plus interest at 2.625% per annum to be repaid with 

360 equal monthly payments of approximately $1,250.17 for principal, interest, and escrow for 

the purchase of a home located at 10406 Brynmore Drive, North Chesterfield, VA 23237. The 

closing costs are to be paid by the Debtor’s spouse and mother-in-law. 

3. The purchase price of the Property is $317,000. 

4. There will be no loan proceeds payable to the Debtor. 

5. The purchase of the Property is in the best interest of the Debtor and will facilitate 

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

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

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 for such other 

and further relief as is just and proper. 

Dated: October 18, 2021 NICOLE DONNETTE STEELEY 

 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 

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CERTIFICATE OF SERVICE 

I hereby certify that on October 18, 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 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 

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IN THE UNITED STATES BANKRUPTCY COURT 

FOR THE EASTERN DISTRICT OF VIRGINIA 

Richmond Division 

 

IN RE: ) 

 ) 

NICOLE DONNETTE STEELEY ) Case No. 19-34628-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 October 20, 2021 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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 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 18, 2021 NICOLE DONNETTE STEELEY 

 By: /s/ James E. Kane 

 Counsel 

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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 

CERTIFICATE OF SERVICE 

I hereby certify that on October 18, 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 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 19-34628-KRH Doc 35 Filed 10/18/21 Entered 10/18/21 14:53:44 Desc Main

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}bk1{Credito AresMatix}bk{

Alfredo Sunga

c/o JFB Management

410 N. Ridge Rd. Suite 100

Henrico, VA 23229

Ballato Law Firm

3721 Westerre Parkway

Suite A

Henrico, VA 23233

Bank of America

Attn: Bankruptcy

P.O. 982284

El Paso, TX 79998

Capital One

Attn: Bankruptcy

Po Box 30285

Salt Lake City, UT 84130

Capital One Auto Finance

Attn: Bankruptcy

Po Box 30285

Salt Lake City, UT 84130

Carmel Holding Co

10660 Argonne Dr.

Glen Allen, VA 23060

Check Into Cash

3059 Mechanicsville Tnpk

Richmond, VA 23223

City of Richmond

Parking Tickets

P.O. Box 26508

Richmond, VA 23261

City of Richmond

900 E Broad Street

Room 109 Deliquent Taxes

Richmond, VA 23219

CJW Medical Center

PO Box 99400

Louisville, KY 40269

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Continental Finance Company

Attn: Bankruptcy

Po Box 8099

Newark, DE 19714

Credit Acceptance

25505 W. Twelve Mile Rd

Ste. 3000

Southfield, MI 48034

Emergency Coverage Corp.

c/o ARS

PO Box 8668

Coral Springs, FL 33075-8668

Express Lanes

PO Box 28148

New York, NY 10087

First Premier Bank

Attn: Bankruptcy

Po Box 5524

Sioux Falls, SD 57117

Focused Recovery Solutions

9701-Metropolitan Ct

Ste B

North Chesterfield, VA 23236

Genesis Bc/celtic Bank

Attn: Bankruptcy

268 South State Street Ste 300

Salt Lake City, UT 84111

Internal Revenue Service

P.O. Box 7346

Philadelphia, PA 19101

Mariner Finance

13102 Midlothian Tnpk.

Midlothian, VA 23113

Maryland Transportation Auth.

PO Box 17600

Baltimore, MD 21297

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NetCredit

175 W. Jackson Blvd., Suite 1000

Chicago, IL 60604

New York State Dept of Tax

NYS Assesment Receivables

P.O. Box 4127

Binghamton, NY 13902

NYC Housing Authority

250 Broadway, 9th Floor

New York, NY 10007

PayPal

PO Box 105658

Atlanta, GA 30348-5658

Paypal

ATTN BANKRUPTCY

Po Box 45950

Omaha, NE 68145

Plaza Services, Llc

Attn: Bankruptcy

110 Hammond Dr. Ste 110

Atlanta, GA 30328

Professional Account Mgmt

386 Pickett St

PO Box 22147

Alexandria, VA 22304

Radiology Assoc of Richmond

PO Box 13343

Richmond, VA 23225

Receivables Management Systems

PO Box 17305

Richmond, VA 23226

Shawn C. Tuthill

c/o Liberty Homes Inc

8249 Crown Colony Parkway A

Mechanicsville, VA 23116

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Square Inc.

1455 Market St.

Suite 600

San Francisco, CA 94103

The Port Authority

PO Box 15183

Albany, NY 12212

Violations Processing Center

EZ-Pass NY

P.O. Box 15186

Albany, NY 12212

Virginia Dept. of Taxation

P O Box 2156

Richmond, VA 23218

Wells Fargo Dealer Services

Attn: Bankruptcy

Po Box 19657

Irvine, CA 92623

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