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: ) 

 ) 

EDWIN CASTELLA CHANDLER ) Case No. 19-36701-KRH 

 ) Chapter 13 

 Debtor ) 

DEBTOR’S OBJECTION TO CLAIM NUMBER 6 

 COMES NOW, the Debtor, by counsel, pursuant to 11 U.S.C. § 502(a) and Bankruptcy 

Rule 3007, and for his Objection to Claim Number 6 by Credit Acceptance Corporation, states as 

follows: 

1. The Debtor hereby objects to Claim Number 6 by Credit Acceptance Corporation 

for a purported debt in the amount of $19,789.67 (“Claim”), on the grounds that the debt listed in 

the proof of claim is barred by the statute of limitations. See VA Code Ann. § 8.01-246. 

2. The Claim is for a deficiency balance on a vehicle loan where the vehicle was 

repossessed and sold at auction in or about October 2004 and the five-year statute of limitations 

for the enforcement of this Claim expired not later than October 2009. 

3. The claimant has not obtained a judgment on the debt and therefore the 

enforcement of this debt is barred and a claim cannot be made on this debt in this case. 

Case 19-36701-KRH Doc 14 Filed 01/28/20 Entered 01/28/20 11:14:45 Desc Main

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WHEREFORE, the Debtor respectfully requests that the foregoing objection be 

sustained, that Claim Number 6 by Credit Acceptance Corporation be disallowed, and for such 

other relief as the Court deems appropriate. 

 EDWIN CASTELLA CHANDLER 

 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 19-36701-KRH Doc 14 Filed 01/28/20 Entered 01/28/20 11:14:45 Desc Main

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CERTIFICATE OF SERVICE 

I hereby certify that on January 28, 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 a copy hereof by first class 

mail, postage prepaid, to: 

Credit Acceptance Corporation 

c/o Corporation Service Company, R/A 

100 Shockoe Slip, Floor 2 

Richmond, VA 23219 

Credit Acceptance Corporation 

25505 W. 12 Mile Road, Suite 3000 

Southfield, MI 48034 

 /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 19-36701-KRH Doc 14 Filed 01/28/20 Entered 01/28/20 11:14:45 Desc Main

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IN THE UNITED STATES BANKRUPTCY COURT 

FOR THE EASTERN DISTRICT OF VIRGINIA 

Richmond Division 

 

IN RE: ) 

 ) 

EDWIN CASTELLA CHANDLER ) Case No. 19-36701-KRH 

 ) Chapter 13 

 Debtor ) 

NOTICE OF OBJECTION TO CLAIM 

 The above Debtor has filed an objection to your claim in the above bankruptcy case. 

 Your claim may be reduced, modified or eliminated. You should read these papers 

carefully and discuss them with your attorney, if you have one.

 If you do not want the court to change or eliminate your claim, then, within thirty (30) 

days of service of this Notice you or your attorney must: 

 File with the court, at the address shown below, a written response to the 

objection and request for a hearing. Unless a written response is filed and 

served by the date specified, the court may decide that you do not oppose the 

objection to your claim. If you mail your response to the court for filing, you 

must mail it early enough so that the court will receive it on or before the date 

stated above. 

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 to be scheduled at a later date. You will receive a separate 

notice of hearing. If no timely response has been filed opposing the relief 

requested, the court may grant the relief without holding a hearing. 

 If you or your attorney do not take these steps, the court may decide that you do not 

oppose the objection to your claim. 

Case 19-36701-KRH Doc 14 Filed 01/28/20 Entered 01/28/20 11:14:45 Desc Main

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Date: January 28, 2020 EDWIN CASTELLA CHANDLER 

 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 19-36701-KRH Doc 14 Filed 01/28/20 Entered 01/28/20 11:14:45 Desc Main

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CERTIFICATE OF SERVICE 

I hereby certify that on January 28, 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 a copy hereof by first class 

mail, postage prepaid, to: 

Credit Acceptance Corporation 

c/o Corporation Service Company, R/A 

100 Shockoe Slip, Floor 2 

Richmond, VA 23219 

Credit Acceptance Corporation 

25505 W. 12 Mile Road, Suite 3000 

Southfield, MI 48034 

 /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 19-36701-KRH Doc 14 Filed 01/28/20 Entered 01/28/20 11:14:45 Desc Main

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