Susan H. Call, Esquire

Staff Counsel for

Carl M. Bates

P.O. Box 1819

Richmond, VA 23218-1819

(804) 237-6800

VSBN 34367

UNITED STATES BANKRUPTCY COURT

EASTERN DISTRICT OF VIRGINIA

RICHMOND DIVISION

In re: Shannon Dawn Harris ) Case No: 21-30071

) Chapter 13

OBJECTION TO CONFIRMATION

 COMES NOW, Susan H. Call, Counsel for Carl M. Bates the Chapter 13 Trustee, and moves this 

Court to deny confirmation of the Chapter 13 Plan filed on January 25, 2021, for the cause as follows:

1. The Debtor filed this Chapter 13 Petition on January 11, 2021 under 11 U.S.C. Chapter 13, now 

pending in the United States Bankruptcy Court, Eastern District of Virginia, Richmond Division.

2. This Objection is filed pursuant to 11 U.S.C. 1325 (b) (1) (B).

3. The above filed Chapter 13 Plan fails to provide that all of the debtor’s projected disposable income 

in the applicable commitment period will be applied to the plan payments, shown by:

a. The Trustee requests six months of all paystubs for the debtor to include any paystubs in 

May 2020, and the W-2 form for all her employment in 2020.

b. The Trustee requests current paystubs.

c. The debtor testified she has not filed her 2018 taxes, and it is suggested that she file those 

taxes, and all tax liability be addressed. 

d. The Chapter 13 Trustee would suggest that all required income be paid into the Chapter 13 

Plan. 

WHEREFORE, for the reasons stated herein, the Chapter 13 Trustee, by Counsel, Susan H. Call, 

respectfully moves the Court to deny confirmation of the Debtors’ proposed Chapter 13 Plan as filed with the 

Court, and for such further and other relief as in the premises may seem just.

Date: February 22, 2021 /s/Susan H. Call

Susan H. Call, Counsel for

Carl M. Bates

Chapter 13 Trustee

Certificate of Service

I hereby certify that on February 22, 2021, I have mailed or hand-delivered a true copy of the foregoing 

Objection to Confirmation to the debtor(s), Shannon Dawn Harris, 5300 Glenside Dr, #601, Henrico, VA 23228

and electronically sent to debtor’s attorney, James E. Kane, Esquire, jkane@kaneandpapa.com.

/s/Susan H. Call

Susan H. Call, Counsel for

Carl M. Bates, Chapter 13 Trustee

Case 21-30071-KRH Doc 20 Filed 02/22/21 Entered 02/22/21 15:32:10 Desc Main

Document Page 1 of 3
Susan H. Call, Esquire

Staff Counsel for

Carl M. Bates

P.O. Box 1819

Richmond, VA 23218-1819

(804) 237-6800

VSBN 34367

UNITED STATES BANKRUPTCY COURT

EASTERN DISTRICT OF VIRGINIA

RICHMOND DIVISION

In re: Shannon Dawn Harris ) Case No: 21-30071

) Chapter 13

Debtor Address 5300 Glenside Dr, #601

Henrico, VA 23228

Last four digits of Social Security No(s).: 9244

NOTICE OF OBJECTION TO CONFIRMATION

Susan H. Call, Counsel for Carl M. Bates the Chapter 13 Trustee, has filed papers with the Court

objecting to confirmation of your Chapter 13 Plan, which was filed in this case.

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 request for a hearing [or a written 

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

Clerk of Court

United States Bankruptcy Court

701 East Broad Street, Suite 4000

Richmond, VA 23219

You must also mail a copy to:

Susan H. Call, Counsel for 

Carl M. Bates

Chapter 13 Trustee

P.O. Box 1819

Richmond, VA 23218

Case 21-30071-KRH Doc 20 Filed 02/22/21 Entered 02/22/21 15:32:10 Desc Main

Document Page 2 of 3
Susan H. Call, Esquire

Staff Counsel for

Carl M. Bates

P.O. Box 1819

Richmond, VA 23218-1819

(804) 237-6800

VSBN 34367

Attend a hearing to be scheduled at a later date. You will receive separate notice of hearing. If 

no timely response has been filed opposing the relief requested, the court may grant the relief without 

holding a hearing.

 X Attend the hearing on the objection scheduled to be held on March 10, 2021 at 11:10 am at 

United States Bankruptcy Court, 701 East Broad Street, Richmond, VA 23219, Room 5000.

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 22, 2021 /s/Susan H. Call

Susan H. Call, Counsel for 

Carl M. Bates

Chapter 13 Trustee

P.O. Box 1819

Richmond, VA 23218-1819

VSBN 34367

Certificate of Service

I hereby certify that on February 22, 2021, I have mailed or hand-delivered a true copy of the foregoing 

Notice of Objection to Confirmation to the debtor(s) Shannon Dawn Harris, 5300 Glenside Dr, #601, Henrico, 

VA 23228 and electronically sent to debtor’s attorney, James E. Kane, Esquire, jkane@kaneandpapa.com.

/s/Susan H. Call

Susan H. Call, Counsel for

Carl M. Bates

Chapter 13 Trustee

Case 21-30071-KRH Doc 20 Filed 02/22/21 Entered 02/22/21 15:32:10 Desc Main

Document Page 3 of 3