Kevin M. Fitzpatrick, Esquire (VSB #30716) 

4118 Leonard Drive, Suite 200 

Fairfax, VA 22030 

(703) 352-7150 

Counsel for Plaintiff Automotive Finance Corporation

 IN THE UNITED STATES BANKRUPTCY COURT 

 FOR THE EASTERN DISTRICT OF VIRGINIA 

 Alexandria Division 

IN RE: ) 

 ) 

SALIM ZAMANI, ) Case No. 17-11618-KHK 

 ) (Chapter 7) 

 Debtor. ) 

 ) 

 ) 

AUTOMOTIVE FINANCE CORPORATION, ) 

 ) 

 Plaintiff, ) 

 ) 

 vs. ) Adversary No. 1:17-ap-01085 

 ) Judge: Klinette H. Kindred 

SALIM ZAMANI, ) 

 ) 

 Defendant. ) 

AFFIDAVIT OF KEVIN M. FITZPATRICK IN SUPPORT OF 

PLAINTIFF’S MOTION FOR ENTRY OF DEFAULT JUDGMENT 

COMMONWEALTH OF VIRGINIA, 

AT LARGE, to-wit: 

 THIS DAY personally appeared before me, the undersigned Notary Public, Kevin M. 

Fitzpatrick, Esquire, who being duly sworn, stated the following: 

1. My name is Kevin M. Fitzpatrick, and I am a member of The Fitzpatrick Law 

Office, P.C. I am the authorized agent for Plaintiff Automotive Finance Corporation (“Plaintiff”) 

in this case, and I am duly licensed to practice law in the state of Virginia and in this Court. 

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2. On August 11, 2017, Plaintiff filed its Complaint to Determine Dischargeability of 

Debt Pursuant to 11 U.S.C. §§ 523(a)(2), 523(a)(4), and 523(a)(6) (the “Complaint”) against the 

Defendant Salim Zamani (“Defendant”). 

3. On August 25, 2017, the Court issued an Alias Summons. 

4. On August 28, 2017, I served the Alias Summons by U.S. mail on the Defendant; 

the Defendant’s attorney, Amir Raminpour, in his Chapter 7 case (Case No. 17-11618-KHK); and 

the Trustee in the Defendant’s Chapter 7 case. I filed a Certificate of Service of the Alias Summons 

on August 28, 2017. 

5. The deadline for the Defendant to answer or otherwise respond to the Plaintiff’s 

Complaint was September 25, 2017. As of the date of the Plaintiff’s Motion for Entry of Default 

Judgment, the Defendant had not answered or otherwise responded to the Plaintiff’s Complaint. 

6. The Clerk of the Bankruptcy Court entered a default against the Defendant on 

November 1, 2017. 

7. Upon information and belief, the Defendant is not in the military service and 

protected by the Servicemembers Civil Relief Act, P.L. 108-109, nor is he an infant or an 

incompetent person. 

8. As set forth in the Declaration of Debt in Support of Plaintiff’s Motion for Entry of 

Default Judgment, attached to the Plaintiff’s Motion for Entry of Default Judgment as Exhibit A, 

the amount due and owing from the Defendant to the Plaintiff is $358,168.03, which is comprised 

of (a) $344,335.32 in principal, (b) $6,899.71 in interest, and (c) $6,933 in fees. 

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9. The Plaintiff is not seeking attorneys’ fees in this case. 

 /s/ Kevin M. Fitzpatrick 

 Kevin M. Fitzpatrick, Esquire 

COMMONWEALTH OF VIRGINIA 

COUNTY OF FAIRFAX 

 The foregoing Affidavit was sworn to and acknowledged before this date, November 24, 

2017, by Kevin M. Fitzpatrick, Esquire, authorized agent for Plaintiff Automotive Finance 

Corporation. 

 /s/ Layla Harb 

 Notary Public 

 Commonwealth of Virginia 

 Reg. # 353338 

 My Commission Expires: 6/30/2020 

 

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