M. Christine Maggard, VSB# 33824

Brock & Scott, PLLC

8757 Red Oak Blvd., Suite 150

Charlotte, NC 28217

christine.maggard@brockandscott.com

Counsel for the Movant

UNITED STATES BANKRUPTCY COURT

EASTERN DISTRICT OF VIRGINIA

RICHMOND DIVISION

In re:

REGINALD BRIAN SUTTON 

AND LATESHA MICHELE 

SUTTON,

Address: 710 LA VON DR

RICHMOND, VA 23227-2229

Debtor(s).

CASE NO: 19-30370-KRH

CHAPTER 13

TRUIST BANK, SUCCESSOR BY MERGER 

TO SUNTRUST BANK

Plaintiff,

v.

REGINALD BRIAN SUTTON AND 

LATESHA MICHELE SUTTON,

Debtor(s)

CARL M. BATES

Trustee

 Defendants.

CERTIFICATE OF COMPLIANCE

Upon information provided by the Movant, undersigned counsel hereby files this 

Certificate of Compliance with respect to the Notice of Default filed with the Court on January 27, 

2020. Movant respectfully represents as follows:

1. The Movant is the holder of a note secured by real property located at 710 La Von 

Drive, Richmond, VA 23227 (the “Property”).

2. A Consent Order Modifying Automatic Stay (D.E. 47) dated October 18, 2019 has been 

entered in the present case. Pursuant to the terms of the Consent Order, the Debtor is 

Case 19-30370-KRH Doc 58 Filed 02/14/20 Entered 02/14/20 12:12:14 Desc Main

Document Page 1 of 3
in default for the following payments:

Monthly Payment From December 1, 2019 

To January 1, 2020

@ $1,028.05 each $2,056.10

Less Suspense Balance $743.90 $-743.90

$1,312.20

3. Pursuant to the terms of the Consent Order, unless Debtor cures the default by tendering 

$1,312.20 in certified funds or cashier’s check within fourteen (14) days of the date of 

the Notice of Default (January 27, 2020), the Court can grant relief from the automatic 

stay without further notice.

4. Movant has complied with the terms of the herein referenced Consent Order and Debtor 

have failed to cure the default as stated in the Notice of Default.

5. Movant requests that this Court grant it relief from the automatic stay without further 

need of notice or hearing and that it be permitted to seek foreclosure on the real property 

located at 710 La Von Drive, Richmond, VA 23227 (the “Property”) consistent with 

its Motion for Relief previously filed herein as Docket Entry #31.

Dated: February 14, 2020 Respectfully Submitted,

/s/ M. Christine Maggard

M. Christine Maggard, VSB# 33824

Brock & Scott, PLLC

8757 Red Oak Blvd., Suite 150

Charlotte, NC 28217

christine.maggard@brockandscott.com

Counsel for the Movant

Case 19-30370-KRH Doc 58 Filed 02/14/20 Entered 02/14/20 12:12:14 Desc Main

Document Page 2 of 3
CERTIFICATE OF SERVICE

The foregoing certificate was endorsed by and/or served upon all necessary parties 

pursuant to Local Rules by electronic notification and/or U.S. First Class Mail, postage pre-paid.

Suad Bektic

98 Alexandria Pike, Suite 10

Warrenton, VA 20186

Counsel for Debtor

REGINALD BRIAN SUTTON

710 LA VON DR

RICHMOND, VA 23227-2229

Debtor

LATESHA MICHELE SUTTON

710 LA VON DR

RICHMOND, VA 23227-2229

Debtor

Carl M. Bates

P. O. Box 1819

Richmond, VA 23218

Trustee

/s/ M. Christine Maggard

M. Christine Maggard, VSB# 33824

Brock & Scott, PLLC

8757 Red Oak Blvd., Suite 150

Charlotte, NC 28217

christine.maggard@brockandscott.com

Counsel for the Movant

Case 19-30370-KRH Doc 58 Filed 02/14/20 Entered 02/14/20 12:12:14 Desc Main

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