Elizabeth C. Brogan

Counsel for Suzanne E. Wade, Chapter 13 Trustee

Virginia State Bar Number 76539

7202 Glen Forest Drive, Suite 202

Richmond, Virginia 23226

(804) 775-0979

UNITED STATES BANKRUPTCY COURT

EASTERN DISTRICT OF VIRGINIA

RICHMOND DIVISION

 In re: Michael E. Rivenbark, Debtor ) Case No. 19-36609-KRH

 ) Chapter 13

OBJECTION TO CONFIRMATION

COMES NOW Elizabeth C. Brogan, Counsel for Suzanne E. Wade, Chapter 13 Trustee, and 

moves this Court to deny confirmation of the Chapter 13 Plan (the “Plan”) dated December 23, 2019, 

for the cause as follows:

1. The Debtor filed this Chapter 13 Petition, now pending in the United States Bankruptcy 

Court, Eastern District of Virginia, Richmond Division, on December 19, 2019 under 11 

U.S.C. Chapter 13.

2. This Objection is filed pursuant to 11 U.S.C. § 1325(a)(4).

3. The above-filed Chapter 13 case is not eligible for confirmation due to the Debtor’s failure 

to provide information regarding his March 2019 transfer of real property. 

4. The Debtor’s Statement of Financial Affairs properly discloses his transfer of real estate 

located at 4025 Frederick Farms Drive in Midlothian, Virginia to his ex-wife, pursuant to a 

property separation agreement (“PSA”). The Trustee requests the Debtor provide a copy of 

the PSA, as well as proof of the mortgage payoff at the time of the transfer.

WHEREFORE, for the reasons stated herein, the Chapter 13 Trustee, by Counsel, respectfully moves 

the Court to deny confirmation of the Debtor’s proposed Chapter 13 Plan, and for such further and other 

relief as the Court deems necessary.

 Date: February 14, 2020 /s/ Elizabeth C. Brogan . 

 Elizabeth C. Brogan, Counsel for

 Suzanne E. Wade, Chapter 13 Trustee 

Case 19-36609-KRH Doc 15 Filed 02/14/20 Entered 02/14/20 13:01:13 Desc Main

Document Page 1 of 4
Elizabeth C. Brogan

Counsel for Suzanne E. Wade, Chapter 13 Trustee

Virginia State Bar Number 76539

7202 Glen Forest Drive, Suite 202

Richmond, Virginia 23226

(804) 775-0979

CERTIFICATE OF SERVICE

I hereby certify a true copy of the foregoing OBJECTION TO CONFIRMATION was served 

electronically or by first-class mail, postage prepaid, this 14th day of February, 2020, upon the following 

parties:

Michael E. Rivenbark

11524 Genito Road 

Midlothian, VA 23112

Pia J. North, Counsel for Debtor

North Law 

5913 Harbour Park Drive 

Midlothian, VA 23112 

help@pianorth.com

 /s/ Elizabeth C. Brogan . 

 Elizabeth C. Brogan, Counsel for

 Suzanne E. Wade, Chapter 13 Trustee 

Case 19-36609-KRH Doc 15 Filed 02/14/20 Entered 02/14/20 13:01:13 Desc Main

Document Page 2 of 4
Elizabeth C. Brogan

Counsel for Suzanne E. Wade, Chapter 13 Trustee

Virginia State Bar Number 76539

7202 Glen Forest Drive, Suite 202

Richmond, Virginia 23226

(804) 775-0979

UNITED STATES BANKRUPTCY COURT

EASTERN DISTRICT OF VIRGINIA

RICHMOND DIVISION

 In re: Michael E. Rivenbark, Debtor ) Case No. 19-36609-KRH

) Chapter 13

 11524 Genito Road )

 Midlothian, VA 23112 )

)

 XXX-XX-7770 )

NOTICE OF OBJECTION TO CONFIRMATION

Elizabeth C. Brogan, Counsel for Suzanne E. Wade, Chapter 13 Trustee, has filed papers with 

the Court objecting to the confirmation of your Chapter 13 Plan dated December 23, 2019.

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.

If you do not want the Court to grant the relief sought in the Objection, or if you want the Court 

to consider your views on the Objection, then on or before three (3) days before the date of the hearing, 

you or your attorney must:

_X_ File with the Court, at the address shown below, a written response pursuant to Local 

Bankruptcy Rule 9013-1(H). If you mail your response to the Court for filing, you must 

mail it early enough that the Court will receive it on or before the date stated above.

Clerk of Court

United States Bankruptcy Court

701 East Broad Street, Suite 4000

Richmond, Virginia 23219

You must also mail a copy to:

Elizabeth C. Brogan 

Counsel for Suzanne E. Wade, Chapter 13 Trustee

7202 Glen Forest Drive, Suite 202

Richmond, Virginia 23226

_X_ Attend the hearing on the Objection, scheduled to be held on February 26, 2020 at 

11:10 a.m. at United States Bankruptcy Court, 701 East Broad Street, Room 5000, 

Richmond, VA 23219.

Case 19-36609-KRH Doc 15 Filed 02/14/20 Entered 02/14/20 13:01:13 Desc Main

Document Page 3 of 4
Elizabeth C. Brogan

Counsel for Suzanne E. Wade, Chapter 13 Trustee

Virginia State Bar Number 76539

7202 Glen Forest Drive, Suite 202

Richmond, Virginia 23226

(804) 775-0979

If you or your attorney do not take these steps, the Court may decide that you do not oppose the 

relief sought in the Objection, and may enter an order granting that relief.

Date: February 14, 2020 /s/ Elizabeth C. Brogan . 

 Elizabeth C. Brogan, Counsel for

 Suzanne E. Wade, Chapter 13 Trustee

CERTIFICATE OF SERVICE

I hereby certify a true copy of the foregoing NOTICE OF OBJECTION TO CONFIRMATION

was served electronically or by first-class mail, postage prepaid, this 14th day of February, 2020, upon 

the following parties:

Michael E. Rivenbark

11524 Genito Road 

Midlothian, VA 23112

Pia J. North, Counsel for Debtor

North Law 

5913 Harbour Park Drive 

Midlothian, VA 23112 

help@pianorth.com

 /s/ Elizabeth C. Brogan . 

 Elizabeth C. Brogan, Counsel for

 Suzanne E. Wade, Chapter 13 Trustee 

Case 19-36609-KRH Doc 15 Filed 02/14/20 Entered 02/14/20 13:01:13 Desc Main

Document Page 4 of 4