KIMBERLY A. CHANDLER, VSB# 47897

CHANDLER LAW FIRM

P.O. 17586

Richmond, VA 23226

Office: (804) 353-1971

Fax: (804) 723-0954 

Counsel for Debtors

IN THE UNITED STATES BANKRUPTCY COURT

FOR THE EASTERN DISTRICT OF VIRGINIA

Richmond Division 

In re: Case No. 20-33177-KRH

Kandise Nadine Lucas

514 East Williamsburg Road 

 Sandston, VA 23150 

SSN/ITTN: xxx-xx-2827 

 Debtor Chapter 13 

NOTICE OF MOTION 

The above Debtor(s) have filed papers with the Court to request an order to Motion to 

Approve Loan Modification Secured by Real Property. 

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.) 

NOTICE IS HEREBY GIVEN THAT A HEARING ON THIS MOTION WILL BE 

HELD AT THE UNITED STATES BANKRUPTCY COURT, U.S. COURTHOUSE, 701 

EAST BROAD STREET, COURTROOM 5000, RICHMOND, VIRGINIA, 23219, ON 

JULY 10, 2024 at 12:00 P.M.

(1) Principal Balance of before new loan modification is 

$34,117.86;

(2) Principal Balance of after loan modification is $39,887.88 

(inclusive of pre-petition and post-petition arrears and 

unpaid interest); 

(3) Interest rate is before loan modification 7.375%; 

(4) Interest rate is after loan modification 6.875%;

(5) Maturity Date before loan modification 7/1/2031;

(6) Maturity Date after loan modification 6/1/2054; 

(7) Monthly payment before loan modification $950.04 

included interest and escrow; 

(8) Monthly payment after loan modification $262.03 

including principal and interest and $340.16 escrow; 

(9) The modification results in a lower monthly payment. 

Future plan payments will not increase, given debtor is 

below median. 

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(C) If no objection is filed within the objection period, the court, in its discretion, may 

enter an order endorsed by the chapter 13 trustee approving the loan modification. 

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, within twenty-one (21) days from the date of 

this Notice 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 above, to: 

Clerk of Court 

United States Bankruptcy Court 

701 East Broad Street 

Suite 4000 

Richmond, VA 23219 

You must also mail a copy to: 

CHANDLER LAW FIRM

P.O. Box 17586 

Richmond, VA 23226 

• Attend the hearing scheduled above. 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 relief sought in the motion and may enter an order granting the motion. 

Dated: June 12, 2024 By: /s/ Kimberly A. Chandler 

 Kimberly A. Chandler, VSB# 47897 

CHANDLER LAW FIRM

P.O. Box 17586 

Richmond, VA 23226 

Office: (804) 353-1971 

Fax: (804) 723-0954 

Counsel for Debtor(s) 

 

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CERTIFICATE OF SERVICE

I hereby certify that on June 12, 2024, a copy of the foregoing Notice was 

electronically transmitted and/or mailed to the Chapter 13 Trustee, and to all creditors 

and parties in interest requesting electronic notice.

 /s/Kimberly A. Chandler 

 Counsel for Debtor(s) 

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KIMBERLY A. CHANDLER, VSB# 47897

CHANDLER LAW FIRM

P.O. 17586

Richmond, VA 23226

Office: (804) 353-1971

Fax: (804) 723-0954 

Counsel for Debtors

IN THE UNITED STATES BANKRUPTCY COURT

FOR THE EASTERN DISTRICT OF VIRGINIA

Richmond Division 

In re: Case No. 20-33177-KRH

Kandise Nadine Lucas

514 East Williamsburg Road 

 Sandston, VA 23150 

SSN/ITTN: xxx-xx-2827 

 Debtor Chapter 13 

MOTION TO APPROVE 

LOAN MODIFICATION SECURED BY REAL PROPERTY

COME NOW, the Debtor(s), Kandise Nadine Lucas, FKA Kandise Thomas-Humphrey by 

counsel, and as for her Motion to Approve Loan Modification of Loan Secured by Real Property 

pursuant to 11 U.S.C. §§ 364(a) and 1304(b), Federal Rules of Bankruptcy Procedure 4001(c) and 9014, 

and Local Bankruptcy Rules 9013-1. In support thereof, Debtor(s) state as follows:

1. This Court has exclusive jurisdiction over this matter pursuant to 28 U.S.C. § 1334. 

2. This proceeding is a core proceeding under 28 U.S.C. §157(b)(2)(A), (B), (K), and (O). 

3. Venue is proper pursuant to 28 U.S.C. § 1409. 

4. On July 23, 2020 (the “Petition Date”), Debtor(s) filed for an order for relief under 

Chapter 13 of the Bankruptcy Code protection pursuant to 11 U.S.C. § 101 et seq. 

5. The Chapter 13 plan, filed August 20, 2020 (the “Plan”), has been confirmed by this 

Court. 

6. The Plan requires Debtor(s) to pay the Chapter 13 Trustee 60 monthly payments for a 

total funding of $27,000.00. 

7. Debtor owns the real estate located at 10906 Sassafras Drive Hopewell, VA 23860 (the 

“Real Property”) and has a fee simple interest described more particularly as:

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8. Upon information and belief, the Real Property is encumbered by lien(s) in favor of 

Servbank, SB, and the present payoff balance(s) are approximately $34,117.86, and current monthly 

payment is $950.04. 

9. Debtor(s) have obtained an interim loan modification agreement, signed by the debtor, 

from Servbank, SB for a refinance/loan modification loan on the Real Property. A copy of the proposed 

Loan Modification is attached as Exhibit “1” and incorporated herein by this reference. The terms of the 

proposed loan are as follows: 

a. Principal Balance of before new loan modification is 

$34,117.86; 

b. Principal Balance of after loan modification is $39,887.88 

(inclusive of pre-petition and post-petition arrears and 

unpaid interest) 

c. Interest rate is before loan modification 7.375%;

d. Interest rate is after loan modification 6.875%;

e. Maturity Date before loan modification 7/1/2031; 

f. Maturity Date after loan modification 6/1/2054; 

g. Monthly payment before loan modification $950.04; 

included interest and escrow; 

h. Monthly payment after loan modification $262.03 

including principal and interest and $340.16 escrow; 

i. The modification results in a lower monthly payment. 

Future plan payments will not increase, given Debtor is 

below median. 

10. Debtor(s) seek permission from the Court for interim Approval of the Loan Modification 

Terms of Loan Secured by Real Property loan modification terms. 

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WHEREFORE, Debtor(s) pray that this Court enter an interim Order Approving the Loan 

Modification Secured by Real Property with terms set forth herein and for such other and further relief 

as the Court deems proper. 

Dated: June 12, 2024 

 By:/s/Kimberly A. Chandler 

 KIMBERLY A. CHANDLER, VSB# 47897

CHANDLER LAW FIRM

P.O. Box 17586 

Richmond, VA 23226 

Office: (804) 353-1971 

Fax: (804) 723-0954 

Counsel for Debtor(s) 

 

CERTIFICATE OF SERVICE

I hereby certify that on June 12, 2024, a copy of the foregoing Motion was electronically 

transmitted and/or mailed to the standing Chapter 13 Trustee and to all creditors and parties in interest. 

 By: /s/Kimberly A. Chandler 

Counsel for the Debtor(s) 

 

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IN THE UNITED STATES BANKRUPTCY COURT

FOR THE EASTERN DISTRICT OF VIRGINIA

Richmond Division 

In re: Case No. 20-33177-KRH

Kandise Nadine Lucas

514 East Williamsburg Road 

 Sandston, VA 23150 

SSN/ITTN: xxx-xx-2827 

 Debtor Chapter 13 

Summary of the Proposed Loan Modification 

Original Loan Modified Loan

Principal Amount $34,117.86 $39,887.88

Interest Rate 7.375% 6.875%

Term or Maturity Date 7/1/2031 6/1/2054

Monthly Payment $950.04 $602.19*

2. The modified loan includes future payment changes or balloon payments. The terms 

of any such future payment changes or balloon payments are: 

 

3. The modification results in a higher monthly payment. The source(s) of the funds used 

to make that payment is/are: Current Monthly income and lower trustee payments. 

4. The modification results in a lower monthly payment. Choose one of the following: 

a. The amount of future plan payments will be increased. 

b. The amount of future plan payments will not be increased. 

* Including principal and interest $262.03 plus $340.16 escrow. 

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