___________________________________

Janet M. Meiburger, VA Bar No. 31842

The Meiburger Law Firm, P.C.

1493 Chain Bridge Road, Suite 201

McLean, VA 22101

(703) 556-7871

Counsel for Plaintiff

IN THE UNITED STATES BANKRUPTCY COURT

FOR THE EASTERN DISTRICT OF VIRGINIA

ALEXANDRIA DIVISION

__________________________________________

IN RE: )

)

ALANS CORNER, LLC )

) Case No. 17-12669-BFK

) Chapter 7

Debtors )

__________________________________________)

)

JANET M. MEIBURGER, Trustee, )

)

Plaintiff )

)

v. ) Adv. Pro. No. 17-01132-BFK

)

DISCOVERY STATION, LLC )

)

Defendant )

_________________________________________ )

MOTION FOR ENTRY OF MONEY JUDGMENT

AGAINST DISCOVERY STATION, LLC

Janet M. Meiburger, Trustee, Plaintiff herein, by counsel, hereby moves for entry of a 

money judgment against Discovery Station, LLC (“Discovery Station”), the Defendant herein, 

pursuant to Rule 55(b)(2) of the Federal Rules of Civil Procedure, made applicable by Rule 7055 

of the Federal Rules of Bankruptcy Procedure. In support of this Motion, Plaintiff states as 

follows:

1. A default judgment has been entered against the Defendant, Discovery Station, 

LLC, for rent owed to the Debtor (Docket No.10). However, at the Trustee’s request, the default 

judgment did not establish the amount of rent owed. The Trustee now seeks entry of a money 

judgment as to which the Trustee can begin collection action.

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BACKGROUND

2. On May 15, 2009, the Debtor entered into a lease of the Debtor’s real property 

located at 43184 Town Hall Plaza, Chantilly, Virginia 20152 (the “Property”) with the 

Defendant, Discovery Station, LLC, as tenant (the “Lease”). The Lease provides that the rent 

payable under the Lease was to consist of the debt service on the first mortgage on the Property 

in the amount of $3,832,000.00; the debt service on the U.S. Small Business Administration 

second mortgage on the Property; and the real estate taxes, property owner association dues, 

utilities and insurance on the Property.

3. According to the motion for relief from the automatic stay filed on behalf of 

EagleBank, the holder of the first mortgage, the first mortgage has not been paid since 

December, 2016, and the mortgage was in arrears in the amount of $276,872.73 as of September 

18, 2017. Additional arrearages have occurred since that time.

4. In addition, on information and belief, Discovery Station did not make any 

payments on the SBA mortgage in 2017. However, the Trustee has been unable to determine the 

arrearages on the SBA mortgage.

5. Discovery Station has not made any real estate tax payments since the beginning 

of 2017. As a result, the bankruptcy estate was required to pay $67,200.24 in past due real estate 

taxes at the closing on the sale of the Property, as shown on Exhibit A. 

6. At a minimum, Discovery Station, LLC owes the Debtor $344,072.97 

($276,872.73 + $67,200.24) in unpaid rent under the Lease. Therefore, the Trustee requests that 

a money judgment be entered against Discovery Station, LLC in the amount of $344,072.97.

WHEREFORE, Janet M. Meiburger, Trustee, Plaintiff herein, by counsel, respectfully 

requests that the Court enter a judgment in the amount of $344,072.97 against Discovery Station, 

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LLC, and grant such other and further relief as the Court deems appropriate under the 

circumstances.

Respectfully submitted,

THE MEIBURGER LAW FIRM, P.C.

Dated: July 20, 2018 By: /s/Janet M. Meiburger

Janet M. Meiburger, VSB No. 31842

The Meiburger Law Firm, P.C.

1493 Chain Bridge Road, Suite 201

McLean, VA 22101

(703) 556-7871

Counsel for Plaintiff

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CERTIFICATE OF SERVICE

I hereby certify that on this 20th day of July, 2018, a true and correct copy of the 

foregoing Motion for Entry of Money Judgment against Discovery Station, LLC will be served 

by ECF e-mail pursuant to the applicable Standing Order of the Court and by first class mail, 

postage prepaid, on the following:

Mark S. Albanese

4041 University Drive, Suite 301

Fairfax, VA 22030

Registered Agent for Discovery Station, LLC

Lee Berlin

5313 Kernstown Court

Haymarket, VA 20169

Carolyn H. Berlin

5484 Rodriguez Lane

Haymarket, VA 20169

/s/ Janet M. Meiburger

Janet M. Meiburger

J:\Trustee\Alans Corner, LLC (17-12669)\Adversary Proceeding\Pleadings\Money Judgment.Motion.1.doc

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EXHIBIT A 

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