UNITED STATES BANKRUPTCY COURT

FOR THE

EASTERN DISTRICT OF VIRGINIA

Alexandria Division

In the Matter of:

KEITH ALAN BRYAN

AND

DORRI ALLYSON BRYAN

Debtors

Chapter 13

Case No. 20-11789-KHK

OBJECTION TO CLAIM

NOTICE OF OBJECTION TO CLAIM

AND

NOTICE OF SCHEDULED HEARING ON THIS OBJECTION

To: LoanCare, LLC

3637 Sentara Way

Virginia Beach, VA 23452

M. Christine Maggard

Attorney for LoanCare, LLC

Brock & Scott, PLLC

484 Viking Dr., Ste. 203

Virginia Beach, VA 23452

C T Corporation System

Registered Agent for LoanCare, LLC

4701 Cox Rd., Ste. 285

Glen Allen, VA 23060

Keith Alan Bryan

Dorri Allyson Bryan

21067 St. Louis Rd.

Middleburg, VA 20117 

Ronald J. Aiani

Attorney for Debtors

86 East Lee Street

Warrenton, VA 20186 

You have filed a claim in the amount of $358,844.91 (arrearage of $41,690.45) 

with a Court claim number of 3 in this Chapter 13 case.

Thomas P. Gorman, Chapter 13 Trustee, has filed this objection to your filed claim 

and asks that the remaining balance be disallowed as it is an unliquidated secured claim 

and relief from the stay has been granted by Order entered March 24, 2021. No claim for 

the unsecured or deficiency balance has been filed. 

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 

have an attorney, you may wish to consult one.)

If you do not wish the court to grant the relief sought in the motion, or if you want 

the court to consider your views on the motion, then on or before five business days prior 

to the hearing date, you or your attorney must:

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Objection to Claim, page 2

20-11789-KHK, Keith Alan and Dorri Allyson Bryan

File with the court a written response with supporting memorandum as required by 

Local Bankruptcy Rule 9013-1(H). Unless a written response and supporting 

memorandum are filed and served by the date specified, the Court may deem any 

opposition waived, treat the motion as conceded, and issue an order granting the 

requested relief without further notice or hearing. If you mail your response to the 

court for filing, you must mail it early enough so the court will receive it on or before 

five business days prior to the scheduled hearing. You must mail a copy to the persons 

listed below.

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.

Attend the hearing to be held on August 26, 2021 at 1:30 p.m., in Courtroom III on 

the 3rd floor, United States Bankruptcy Court, 200 South Washington Street, 

Alexandria, VA 22314. If no timely response has been filed opposing the relief 

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

A copy of any written response must be mailed to the following persons:

Thomas P. Gorman

300 North Washington Street, Suite 400

Alexandria, VA 22314

Clerk of the Court

United States Bankruptcy Court

200 South Washington Street

Alexandria, VA 22314

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Objection to Claim, page 3

20-11789-KHK, Keith Alan and Dorri Allyson Bryan

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

oppose objection to your claim.

Date: July 14, 2021 ___/s/ Thomas P. Gorman___

Thomas P. Gorman

Chapter 13 Trustee

300 North Washington Street, #400

Alexandria, VA 22314

(703) 836-2226

VSB 26421

CERTIFICATE OF SERVICE

I hereby certify that I have this 14th day of July, 2021, served via ECF to authorized 

users or mailed a true copy of the foregoing Objection to Claim, Notice of Objection, and 

Notice of Hearing to the parties listed in the heading hereof.

/s/ Thomas P. Gorman_____

Thomas P. Gorman

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