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: ) 

 ) 

LAWRENCE HENDERSON THOMAS ) Case No. 21−30247−KLP 

 ) Chapter 13 

 Debtor ) 

DEBTOR’S RESPONSE TO OBJECTION 

TO CONFIRMATION OF CHAPTER 13 PLAN 

 COMES NOW, the Debtor, by counsel, and in response to the Objection to Confirmation 

of Chapter 13 Plan (“Objection”) filed by Chanell Thomas herein, states as follows: 

1. The Debtor denies the allegations contained in Paragraph 1 of the Objection on 

the grounds that Chanell Thomas is not a secured creditor and the Property Settlement 

Agreement referenced therein is not “perfected” as alleged. 

2. The Debtor denies the allegations contained in Paragraph 2 of the Objection on 

the grounds that Chanell Thomas is not a secured creditor. The Debtor further states that he has 

filed an objection to Claim Number 6 by Chanell Thomas for a purported priority tax debt 

pursuant to 11 U.S.C. § 507(a)(8) in the amount of $5,078.39 (“Claim”), on the grounds that the 

Claim is not a priority tax debt. Chanell Thomas is an individual, not a governmental unit 

entitled to priority status as required by 11 U.S.C. § 507(a)(8). Chanell Thomas’ claim is for the 

Debtor’s obligation to pay a joint tax debt under a property settlement agreement, which is a 

general unsecured claim. 

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3. The Debtor denies the allegations contained in Paragraph 3 of the Objection on 

the grounds that Chanell Thomas is not a secured creditor. The Debtor further states that he has 

property scheduled and the Plan is treating the IRS as a priority creditor in the amount of 

$500.00 and an general unsecured creditor in the amount of $6,000, which is proper under 11 

U.S.C. 1325. 

4. The Debtor denies the allegations contained in Paragraph 4 of the Objection on 

the grounds that Chanell Thomas is not a secured creditor. The Debtor further states that 

Chanell Thomas is not entitled to interest on her claim. 

5. The Debtor denies the allegations contained in Paragraph 5 of the Objection and 

demands strict proof thereof. 

WHEREFORE, the Debtor respectfully requests that the Objection to Confirmation of 

Chapter 13 Plan filed by Chanell Thomas be overruled, that the Chapter 13 Plan filed herein be 

confirmed, and for such other relief as the Court deems appropriate. 

LAWRENCE HENDERSON THOMAS 

 

 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 

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CERTIFICATE OF SERVICE 

I hereby certify that on March 20, 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 a copy hereof by first class 

mail, postage prepaid, to: 

Chanell Thomas 

3827 Ruslander Ct. 

Richmond, VA 23223 

 /s/ James E. Kane 

 James E. Kane 

Case 21-30247-KLP Doc 22 Filed 03/20/21 Entered 03/20/21 11:47:49 Desc Main

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