James E. Kane (VSB# 30081) 

Kane & Papa, P.C. 

P. O. Box 508 

Richmond, Virginia 23218-0508 

Telephone (804) 225-9500 

Counsel for Debtor 

IN THE UNITED STATES BANKRUPTCY COURT 

FOR THE EASTERN DISTRICT OF VIRGINIA 

Richmond Division 

IN RE: ) 

 ) 

KELLY ANJEL SALAT ) Case No. 20-31633-KRH 

) Chapter 13 

 Debtor ) 

NOTICE OF MOTION TO IMPOSE THE AUTOMATIC STAY AND HEARING 

The above-named Debtor, by counsel, has filed a Motion to Impose the Automatic Stay 

with the Court pursuant to 11 U.S.C. § 362(c)(4)(B). Your rights may be affected. You should 

read these papers carefully and discuss them with your attorney, if you have one. 

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

ON April 8, 2020 at 12:00 p.m. in Honorable Kevin R. Huennekens’ Courtroom, U.S. 

Bankruptcy Court, 701 E. Broad Street, Room 5000, Richmond, VA 23219. 

If you want to be heard on this matter, then no later than three (3) days before the date of 

the hearing, you or your attorney must: 

1. File with the court, at the address below, a written response pursuant to Local Rule 

9013-1(H). If you mail your response to the Court for filing, you must mail it early enough so 

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

Clerk of Court 

United States Bankruptcy Court 

701 E. Broad Street, Room 4000 

Richmond, VA 23219-3515 

2. You must also mail a copy to: 

 James E. Kane, Esquire 

 Kane & Papa, PC 

 P.O. Box 508 

 Richmond, VA 23218 

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 that relief. 

Case 20-31633-KRH Doc 8 Filed 03/25/20 Entered 03/25/20 17:38:00 Desc Main

Document Page 1 of 6
2 

Respectfully submitted, 

KELLY ANJEL SALAT 

By Counsel 

/s/ James E. Kane 

James E. Kane (VSB# 30081) 

Kane & Papa, P.C. 

P. O. Box 508 

Richmond, Virginia 23218-0508 

Telephone (804) 225-9500 

Counsel for Debtor 

CERTIFICATE OF SERVICE 

I certify that on March 25, 2020, I have transmitted a true copy of the foregoing 

document electronically through the Court’s CM/ECF system or by mail to the Debtors, Chapter 

13 trustee, the United States trustee if other than by the electronic means provided for at Local 

Bankruptcy Rule 2002-1, all attorneys appearing in the previous case as listed below, and to all 

creditors and parties in interest of the mailing matrix attached hereto. 

/s/ James E. Kane 

Counsel for Debtor 

Case 20-31633-KRH Doc 8 Filed 03/25/20 Entered 03/25/20 17:38:00 Desc Main

Document Page 2 of 6
3 

IN THE UNITED STATES BANKRUPTCY COURT 

FOR THE EASTERN DISTRICT OF VIRGINIA 

Richmond Division 

IN RE: ) 

 ) 

KELLY ANJEL SALAT ) Case No. 20-31633-KRH 

) Chapter 13 

 Debtor ) 

MOTION TO IMPOSE AUTOMATIC STAY 

COMES NOW KELLY ANJEL SALAT (the “Debtor”), by counsel, pursuant to 11 

U.S.C. § 362(c)(4)(B) and files the following Motion to Impose Automatic Stay, and 

affirmatively states as follows: 

1. Jurisdiction of this Court over the instant matter is based upon 28 U.S.C. §§ 1334 

and 157 in that this action arises in and relates to the bankruptcy case of the Debtors. 

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 March 20, 2020 (hereinafter the “Petition Date”), the Debtor filed a petition 

for relief under Chapter 13 of the Bankruptcy Code (the “instant case”). 

5. Within the year prior to filing the instant case, Debtor has been a debtor in two (2) 

pending Chapter 13 bankruptcy cases which were dismissed. 

WHEREFORE, the Debtor, KELLY ANJEL SALAT respectfully requests this 

Honorable Court to enter an Order imposing the automatic stay as to all creditors, as to Debtor 

and the Debtor’s property, and as to the property of the estate for the duration of the instant case, 

and for such other and further relief as to the Court shall be deemed appropriate. 

Case 20-31633-KRH Doc 8 Filed 03/25/20 Entered 03/25/20 17:38:00 Desc Main

Document Page 3 of 6
4 

Respectfully submitted, 

KELLY ANJEL SALAT 

By Counsel: 

/s/ James E. Kane 

James E. Kane (VSB# 30081) 

Kane & Papa, P.C. 

P. O. Box 508 

Richmond, Virginia 23218-0508 

Telephone (804) 225-9500 

Counsel for Debtor 

CERTIFICATE OF SERVICE 

I certify that on March 25, 2020, I have transmitted a true copy of the foregoing 

document electronically through the Court’s CM/ECF system or by mail to the Debtor, Chapter 

13 trustee, the United States trustee if other than by the electronic means provided for at Local 

Bankruptcy Rule 2002-1, all attorneys appearing in the previous case as listed below, and to all 

creditors and parties in interest of the mailing matrix attached hereto. 

/s/ James E. Kane 

Counsel for Debtor 

Case 20-31633-KRH Doc 8 Filed 03/25/20 Entered 03/25/20 17:38:00 Desc Main

Document Page 4 of 6
}bk1{CreditoAsMarix}bk{

Club Land'or Limited

2120 Staples Mill Road

Richmond, VA 23230

ECMC

P O Box 16478

Lock Box 8682

Saint Paul, MN 55116

FedLoan Servicing

Attn: Bankruptcy

Po Box 69184

Harrisburg, PA 17106

Global Payments

Po Box 66118

Chicago, IL 60666

I C System Inc

Attn: Bankruptcy

Po Box 64378

St Paul, MN 55164

Land'or International, Inc.

2120 Staples Mill Road

Suite 300

Richmond, VA 23230

Midland Funding

2365 Northside Dr Ste 300

San Diego, CA 92108

National Credit Adjusters LLC

Attn: Chassity Lindeman

PO Box 3023

Hutchinson, KS 67504

Select Portfolio Servicing

P.O. Box 65450

Salt Lake City, UT 84165

Virginia Department of Taxatio

PO Box 2369

Richmond, VA 23218

Case 20-31633-KRH Doc 8 Filed 03/25/20 Entered 03/25/20 17:38:00 Desc Main

Document Page 5 of 6
Wells Fargo Dealer

PO Box 25341

Santa Ana, CA 92799

Case 20-31633-KRH Doc 8 Filed 03/25/20 Entered 03/25/20 17:38:00 Desc Main

Document Page 6 of 6