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UNITED STATES BANKRUPTCY COURT

FOR THE

EASTERN DISTRICT OF VIRGINIA

Alexandria Division

In the Matter of: :

:

: Chapter 7

THE MORGAN CENTER, INC., :

: Case No. 19-13278-BFK

Debtor. :

:

OBJECTION TO CLAIM OF CAMPBELL FLANNERY, P.C.

COMES NOW Michael Handberg (“Handberg”), by counsel, and files this Objection to the 

proof of claim #3-1 filed herein by Campbell Flannery, P.C. (“CFP”), and does object to the proof of 

claim filed by CFP for the reasons set forth hereinbelow. 

1. The Debtor, The Morgan Center, Inc. (“TMC”), commenced this case by the 

filing of a voluntary petition for relief pursuant to Chapter 7 of the Bankruptcy Code on October 

8, 2019 (the “Petition Date”). Janet M. Meiburger (“Trustee”) has been appointed and remains as

the duly qualified and acting Chapter 7 Trustee in this case. On January 22, 2020, this Court 

entered an order substantively consolidating this case with the related Chapter 7 case of Northern 

Virginia Advocacy Counseling (“NVAC”), case #19-13319-BFK with the TMC case designated 

as the lead case. 

2. The Trustee has indicated that there are assets in the consolidated case and has 

requested that the Clerk of the Court set a bar date for filing proofs of claims herein. The bar date 

for filing proofs of claims was set for May 15, 2020 (the “Bar date”).

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3. Handberg is a judgment creditor of TMC and has also asserted claims against the 

related entity NVAC. Handberg has filed proofs of claims in each of the consolidated cases 

herein.

4. CFP has filed a proof of claim which has been docketed on the claims register of 

this proceeding as Claim #03-1. The proof of claim filed by CFP alleges a claim for legal fees 

related to joint representation of TMC, NVAC and their principal, Felicia Goldberg 

(“Goldberg”). 

5. Handberg objects to CFP’s proof of claim filed herein for the following reasons:

a. Handberg has reason to believe that CFP’s joint representation of TMC, 

NVAC and Goldberg was undertaken on a contingent fee basis, predicated 

upon prevailing upon an appeal of a defamation action brought against 

Handberg and prosecuted by CFP on behalf of Goldberg. 

b. Alternatively, Handberg believes and represents that fees payable to CFP 

were the obligation of Goldberg personally, and not the corporate entities. 

c. Handberg further objects on the basis that CFP has failed to provide any 

documentation in support of its alleged claims. The proof of claim filed herein

fails to attach any claimed contract or agreement, any itemized invoices or 

evidence of payment of same, or any other document from which CFP’s 

alleged claim could be confirmed or evaluated. 

6. 11 U.S.C. 502 provides that, upon objection made to a proof of claim, the court 

shall disallow such claim to the extent that “such claim is unenforceable against the debtor and 

property of the debtor, under any agreement or applicable law for a reason other than because 

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such claim is contingent or unmatured, ....” 11 U.S.C. 502(b)(1), emphasis supplied. Handberg 

represents and avers that the proof of claim filed by CFP should be disallowed in full to the 

extent it is shown that CFP undertook representation on a contingent fee basis, or to the extent it 

is shown that Goldberg was principally and personally responsible for payment of any fees and 

expenses incurred by CFP. Alternatively, CFP seeks reduction of the proof of claim filed herein 

to the extent its documents and records fail to support and confirm the amounts set forth therein. 

7. Handberg reserves the right to supplement this Objection. 

MICHAEL HANDBERG

By Counsel

/s/ Kevin M. O’Donnell 

Kevin M. O’Donnell, VSB #30086

Jeffery T. Martin, Jr., VSB #71860

Henry & O’Donnell, P.C.

300 N. Washington Street

Suite 204

Alexandria, Virginia 22314

703-548-2100 telephone

703-548-2105 facsimile

kmo@henrylaw.com

Counsel to Michael Handberg

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CERTIFICATE OF SERVICE

I hereby certify that a true copy of the foregoing pleading was sent via the ECF system to 

counsel for Campbell Flannery, P.C., Debtor’s counsel, the Chapter 7 Trustee, the U.S. Trustee and 

all parties requesting notice herein, and by first class mail, postage prepaid, on this 8th day of May, 

2020 to the Debtor at its address of record herein. 

/s/ Kevin M. O’Donnell

Kevin M. O’Donnell

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