James E. Kane (VSB #30081) 

KANE & PAPA, P.C. 

1313 East Cary Street 

Richmond, VA 23219 

(804) 225-9500 (phone) 

(804) 225-9598 (fax) 

Counsel for Debtor 

IN THE UNITED STATES BANKRUPTCY COURT 

FOR THE EASTERN DISTRICT OF VIRGINIA 

Richmond Division 

 

IN RE: ) 

 ) 

SHAUNA MONE'T MCWILLIAMS ) Case No. 21-31470-KLP 

 ) Chapter 13 

 Debtor ) 

MOTION TO EXPEDITE HEARING ON MOTION 

TO SELL REAL ESTATE AND TO SHORTEN NOTICE PERIOD 

 COME NOW the Debtor, by counsel, and move this Court to Expedite the Hearing on 

Debtor’s Motion to Sell Real Estate and to Shorten Notice Period, and in support thereof states as 

follows: 

 1. The Debtor filed this case under Chapter 13 of the U.S. Bankruptcy Code on May 

3, 2021. 

 2. Truist Bank is a secured creditor which holds a first mortgage on the property 

known as 3818 Beechtree Ct., North Chesterfield, VA 23234, more particularly known as 

ALL THAT CERTAIN LOT, PIECE OR PARCEL WITH IMPROVEMENTS 

THEREON AND APPURTENANCES THERETO BELONGING, LYING, 

BEING AND SITUATE IN COUNTY OF CHESTERFIELD, VIRGINIA, AND 

SHOWN AND DESIGNATED AS LOT 2, BLOCK B, SECTION 1, ON THE 

SUBDIVISION PLAT OF BELFAIR TOWNHOUSES, SECTION 1, 

RECORDED IN THE CLERK’S OFFICE, CIRCUIT COURT, CHESTERFIELD 

COUNTY, VIRGINIA, IN PLAT BOOK 20, PAGES 1 THROUGH 8, TO 

WHICH PLAT REFERENCE IS HEREBY MADE FOR A MORE 

PARTICULAR DESCRIPTION OF THE PROPERTY. 

 (the “Property”). 

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3. The approximate payoff balance on the note secured by said mortgage is 

$91,000.00. The tax assessed value of the Property is $122,800.00. 

 4. Debtor has entered into a contract (“Contract”) for the sale of the Property to 

Melissa Pate for $187,000.00, which, upon closing of the same, will result in Truist Bank 

releasing its deed of trust against the Property. 

 5. The amount of the sale or loan proceeds to be applied to the Debtor’s obligations 

under the confirmed plan is $2,500.00, which will not result in full payment of all allowed 

claims. 

 6. The approximate amount of sales proceeds to be paid to the Debtor is $74,800.00. 

7. Debtor is in the process of purchasing another home for Debtor and Debtor’s 4-

year-old son, and needs the proceeds to pay for moving expenses and down payment for the 

purchase of the new home. 

8. On December 15, 2021, or as soon thereafter as may be practicable, Debtor 

intends to sell Debtor’s interest in the Property in accordance with the terms of the contract. 

WHEREFORE, the Debtor respectfully requests that the Court expedite the hearing on 

the Motion to Sell Real Estate, Shorten the Notice Period required for said Motion, and grant such 

other and further relief as is just and proper. 

Dated: November 24, 2021 SHAUNA MONE'T MCWILLIAMS 

 By: /s/ James E. Kane 

 Counsel 

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James E. Kane (VSB #30081) 

KANE & PAPA, P.C. 

1313 East Cary Street 

Richmond, VA 23219 

(804) 225-9500 (phone) 

(804) 225-9598 (fax) 

Counsel for Debtor 

 

CERTIFICATION

 I, James E. Kane, pursuant to Local Rule 9013-1(N), do hereby certify that: 

 

 1. I have carefully examined the matter and concluded that there is a true need for 

an emergency hearing, 

 2. I have not created the emergency through any lack of due diligence. 

 3. I have made a bona fide effort to resolve the matter without hearing. 

By: /s/ James E. Kane__________ 

 James E. Kane 

CERTIFICATE OF SERVICE 

I hereby certify that on November 24, 2021, I will electronically file the foregoing with 

the Clerk of Court using the CM/ECF system, which will then send a notification of such filing 

(NEF) to all parties registered to receive notice thereof and will mail the same by first class mail, 

postage pre-paid, to the parties on the attached list. 

/s/ James E. Kane 

Counsel for Debtor 

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IN THE UNITED STATES BANKRUPTCY COURT 

FOR THE EASTERN DISTRICT OF VIRGINIA 

Richmond Division 

 

IN RE: ) 

 ) 

SHAUNA MONE'T MCWILLIAMS ) Case No. 21-31470-KLP 

 ) Chapter 13 

 Debtor ) 

NOTICE OF MOTION AND HEARING 

 The above Debtor has filed papers with the Court to request an order to Expedite the 

hearing and to Shorten the Notice Period with respect to his Motion to Sell Real Estate. 

 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 motion, or if you want the 

court to consider your views on the motion, then, you or your attorney must: 

 File with the court, at the address shown below, a written request for a hearing [or 

written response pursuant to Local Bankruptcy Rule 9013-1(H)]. If you mail your 

request for a hearing (or response) to the court for filing, you must mail it early 

enough so the court will receive it on or before the date stated above, to: 

Clerk of Court 

United States Bankruptcy Court 

701 East Broad Street 

Richmond, VA 23219 

You must also mail a copy to: 

James E. Kane, Esquire 

KANE & PAPA, P.C. 

1313 East Cary Street 

Richmond, Virginia 23219 

 Attend a hearing scheduled for December 8, 2021 at 10:00 a.m. at U.S. 

Bankruptcy Court, 701 East Broad Street, Room 5100, Richmond, VA 

23219. If no timely response has been filed opposing the relief requested, the 

court may grant the relief without holding a hearing. 

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 REMOTE HEARING INFORMATION: 

Due to the COVID−19 public health emergency, no in-person hearings are being 

held. 

This hearing will take place remotely through Zoom on the date and time scheduled 

herein. 

To appear at the hearing, you must send, by email, a completed request form (the 

“Zoom Request Form”), which is available on the Court's internet website at 

www.vaeb.courts.gov, on the page titled, “Temporary Emergency Provisions 

Regarding ZoomGov Remote Proceeding Access Information.” Email your 

completed Zoom Request Form to the email address listed for the Judge assigned to 

the case. Following receipt of your Zoom Request Form, Court staff will respond to 

the email address from which the request was submitted with additional information 

on how to participate through Zoom. 

***The email address shall be used only to submit Zoom Request Forms. No other 

matters or requests will be considered by Court staff, and under no circumstances will 

any such matters or requests be brought to the Judge’s attention. Failure to comply 

with these instructions may result in appropriate action, including but not limited to 

the imposition of sanctions. 

*** PLEASE NOTE: You MUST submit the Zoom Request Form no later than 

two (2) business days prior to this hearing. Any documentary evidence the 

parties wish to present at the hearing must be filed with the Court in advance of 

the hearing.

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 or objection and may enter an order granting that relief. 

Dated: November 24, 2021 SHAUNA MONE'T MCWILLIAMS 

 By: /s/ James E. Kane 

 Counsel 

James E. Kane (VSB #30081) 

KANE & PAPA, P.C. 

1313 East Cary Street 

Richmond, VA 23219 

(804) 225-9500 (phone) 

(804) 225-9598 (fax) 

Counsel for Debtor 

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CERTIFICATE OF SERVICE 

I hereby certify that on November 24, 2021, I will electronically file the foregoing with 

the Clerk of Court using the CM/ECF system, which will then send a notification of such filing 

(NEF) to all parties registered to receive notice thereof and will mail the same by first class mail, 

postage pre-paid, to the parties on the attached list. 

/s/ James E. Kane 

Counsel for Debtor 

Case 21-31470-KLP Doc 22 Filed 11/24/21 Entered 11/24/21 12:49:17 Desc Main

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}bk1{Credito AresMatix}bk{

American Freight

4100 Tomlynn St

Suite A

Richmond, VA 23230

Beechtree Property Owners Asso

210 Lawsons Dr

Clarksville, VA 23927

Blackburn Conte Schilling Clic

300 West Main St.

Richmond, VA 23220

Cashnet USA- Bankruptcy

175 W. Jackson Blvd.

Suite 1000

Chicago, IL 60604

CJW Medical Center

Attn: Bankruptcy

One Park Plaza

Nashville, TN 37203

Laboratory Corp of America

P.O. Box 2240

Burlington, NC 27216

Lendmark Financial Services

1735 North Brown Road

Suite 300

Lawrenceville, GA 30043

OSLA/Dept of Ed

Attn: Bankruptcy

Po Box 18475

Oklahoma City, OK 73154

Radius Global Solutions, LLC

P.O. Box 390846

Minneapolis, MN 55439

Rva Fin Fcu

Attn: Bankruptcy Dept

1700 Robin Hood Rd

Richmond, VA 23220

Case 21-31470-KLP Doc 22 Filed 11/24/21 Entered 11/24/21 12:49:17 Desc Main

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Suntrust Bank

Mailcode VA-RVW-6290

Po Box 8509

Richmond, VA 23286

Suntrust Bank

Attn: Bankruptcy

Mc Va-Rvw_6290 Pob 85092

Richmond, VA 23286

Verizon

Verizon Wireless Bk Admin

500 Technology Dr Ste 550

Weldon Springs, MO 63304

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