James H. Wilson, Jr., VSB No: 27878

Counsel for Debtor

4860 Cox Road, Suite 200

Glen Allen, VA 23060

(804) 740-6464

1

UNITED STATES BANKRUPTCY COURT

EASTERN DISTRICT OF VIRGINIA

Richmond Division

In re: :

:

TA-VON BECKER, : Case No: 20-33765

: Chapter 13

Debtor. :

:

ZACHARY BECKER, :

Movant, :

v. :

:

TA-VON BECKER, : 

SUZANNE E. WADE, TRUSTEE. :

Defendants. :

OBJECTION TO MOTION FOR RELIEF FROM STAY

The objection of Ta-Von Becker, Debtor, to the Motion for Relief from 

Automatic Stay filed herein on June 14, 2021, respectfully states:

1. Debtor admits the allegations contained in paragraphs 1, 2, 3, 4, 5, and 6.

2. Debtor denies the allegations and legal conclusions contained in paragraph 12

and in the prayer for relief.

3. Debtor is without knowledge or information sufficient to form a belief as to 

the truth of the allegations contained in paragraphs 7 and 13, and therefore 

denies the same and demands strict proof thereof.

4. Movant makes legal arguments and states conclusions in the second sentence 

of paragraph 3 and in paragraphs 9, 10 and 11, which do not require a 

response. To the extent any response is required, Debtor denies Movant is 

entitled to the relief requested based on the arguments and conclusions.

Case 20-33765-KLP Doc 52 Filed 06/15/21 Entered 06/15/21 13:38:00 Desc Main

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James H. Wilson, Jr., VSB No: 27878

Counsel for Debtor

4860 Cox Road, Suite 200

Glen Allen, VA 23060

(804) 740-6464

2

5. Movant is currently a debtor in an active chapter 7 asset case administered by 

Lynn Tavenner, trustee. As such, Movant’s request for relief further 

complicates all three cases and unnecessarily raises potential conflicts 

between the proceedings. As an example, title to property determines rights in 

bankruptcy, while title does not necessarily determine rights in marital 

property in equitable distribution, but rather creates presumptions affecting the 

burden of production. See, Va. Code §20-107.3.

6. Movant can obtain a divorce and address support issues without relief from 

the stay. Movant presents no compelling reasons or rationale for allowing the 

divorce to proceed while there are two active bankruptcy cases pending.

7. Equitable distribution of the property and debts of the party can wait until 

Debtor completes her chapter 13 case. In fact, the continuation of the divorce 

case would likely jeopardize Debtor’s completion of the chapter 13 

bankruptcy and thereby prejudice her creditors.

WHEREFORE, Debtor prays of the Court to deny the motion and to issue such

orders, processes, or judgments that are necessary or appropriate to carry out the 

provisions of Title 11.

TA-VON BECKER

By Counsel

Date: June 15, 2021

/s/James H. Wilson, Jr.

James H. Wilson, Jr.

Counsel for Debtor

VSB No: 27878

4860 Cox Road, Suite 200

Glen Allen, VA 23060

(804) 740-6464

Case 20-33765-KLP Doc 52 Filed 06/15/21 Entered 06/15/21 13:38:00 Desc Main

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James H. Wilson, Jr., VSB No: 27878

Counsel for Debtor

4860 Cox Road, Suite 200

Glen Allen, VA 23060

(804) 740-6464

3

PROOF OF SERVICE

I certify that on June 15, 2021, I served a copy of the foregoing Objection on the 

parties listed below, by ECF or first-class mail, postage prepaid:

Suzanne Wade, Chapter 13 Trustee

P. O. Box 1780

Richmond, VA 23218-1780

Klementina Pavlova, Esq.

Sands Anderson PC

PO Box 1998

Richmond, VA 23218-1998

/s/ James H. Wilson, Jr.

James H. Wilson, Jr., VSB No: 27878

Counsel for Debtor

Case 20-33765-KLP Doc 52 Filed 06/15/21 Entered 06/15/21 13:38:00 Desc Main

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