Elizabeth C. Brogan

Counsel for Suzanne E. Wade, Chapter 13 Trustee

Virginia State Bar Number 76539

7202 Glen Forest Drive, Suite 202

Richmond, Virginia 23226

(804) 775-0979

UNITED STATES BANKRUPTCY COURT

EASTERN DISTRICT OF VIRGINIA

RICHMOND DIVISION

 In re: Paul Richard Stewart, Debtor ) Case No. 20-30038-KLP

 ) Chapter 13

OBJECTION TO CONFIRMATION

COMES NOW Elizabeth C. Brogan, Counsel for Suzanne E. Wade, Chapter 13 Trustee, and 

moves this Court to deny confirmation of the Chapter 13 Plan dated January 8, 2020, for the cause as 

follows:

1. The Debtor filed this Chapter 13 Petition, now pending in the United States Bankruptcy 

Court, Eastern District of Virginia, Richmond Division, on January 3, 2020 under 11 U.S.C. 

Chapter 13.

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

3. The above-filed Chapter 13 case is not eligible for confirmation due to the Debtor’s failure 

to provide proof of his household expenses; specifically, the expenses taken as marital 

adjustment at Line 13 of Form 122C-1.

4. The Trustee would suggest, based on the Debtor’s wife’s paystubs from her new, current 

employment, that her payroll taxes appear overstated at Line 13, and that she has no ongoing 

expenses for life insurance or a retirement contribution. 

5. In addition, the Trustee requests the Debtor provide proof of his wife’s monthly debt 

maintenance expenses.

WHEREFORE, for the reasons stated herein, the Chapter 13 Trustee, by Counsel, respectfully moves 

the Court to deny confirmation of the Debtor’s proposed Chapter 13 Plan, and for such further and other 

relief as the Court deems necessary.

 Date: March 4, 2020 /s/ Elizabeth C. Brogan . 

 Elizabeth C. Brogan, Counsel for

 Suzanne E. Wade, Chapter 13 Trustee 
Elizabeth C. Brogan

Counsel for Suzanne E. Wade, Chapter 13 Trustee

Virginia State Bar Number 76539

7202 Glen Forest Drive, Suite 202

Richmond, Virginia 23226

(804) 775-0979

CERTIFICATE OF SERVICE

I hereby certify a true copy of the foregoing OBJECTION TO CONFIRMATION was served 

electronically or by first-class mail, postage prepaid, this 4th day of March, 2020, upon the following 

parties:

Paul Richard Stewart

5854 Pilmour Drive 

Providence Forge, VA 23140

Patrick Thomas Keith, Counsel for Debtor

Boleman Law Firm, PC 

P.O. Box 11588 

Richmond, VA 23230-1588 

ecf@bolemanlaw.com

William R. Baldwin, III, Counsel for Donald R. Stewart

Meyer Baldwin Long & Moore LLP 

5600 Grove Avenue 

Richmond, VA 23226-2102 

billbaldwin@comcast.net

Brandon R. Jordan, Johnie Rush Muncy; Counsel for First Home Mortgage Corporation 

Samuel I. White, P.C. 

1804 Staples Mill Rd., Suite 200

Richmond, VA 23230 

bjordan@siwpc.com; jmuncy@siwpc.com

 /s/ Elizabeth C. Brogan . 

 Elizabeth C. Brogan, Counsel for

 Suzanne E. Wade, Chapter 13 Trustee 
Elizabeth C. Brogan

Counsel for Suzanne E. Wade, Chapter 13 Trustee

Virginia State Bar Number 76539

7202 Glen Forest Drive, Suite 202

Richmond, Virginia 23226

(804) 775-0979

UNITED STATES BANKRUPTCY COURT

EASTERN DISTRICT OF VIRGINIA

RICHMOND DIVISION

 In re: Paul Richard Stewart, Debtor ) Case No. 20-30038-KLP

) Chapter 13

 5854 Pilmour Drive )

 Providence Forge, VA 23140 )

)

 XXX-XX-0975 )

NOTICE OF OBJECTION TO CONFIRMATION

Elizabeth C. Brogan, Counsel for Suzanne E. Wade, Chapter 13 Trustee, has filed papers with 

the Court objecting to the confirmation of your Chapter 13 Plan dated January 8, 2020.

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 response pursuant to Local 

Bankruptcy Rule 9013-1(H). If you mail your response to the Court for filing, you must 

mail it early enough that 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, Virginia 23219

You must also mail a copy to:

Elizabeth C. Brogan

Counsel for Suzanne E. Wade, Chapter 13 Trustee

7202 Glen Forest Drive, Suite 202

Richmond, Virginia 23226

_X_ Attend the hearing on the Objection, scheduled to be held on March 11, 2020 at 

9:10 a.m. at United States Bankruptcy Court, 701 East Broad Street, Room 5100, 

Richmond, VA 23219.
Elizabeth C. Brogan

Counsel for Suzanne E. Wade, Chapter 13 Trustee

Virginia State Bar Number 76539

7202 Glen Forest Drive, Suite 202

Richmond, Virginia 23226

(804) 775-0979

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: March 4, 2020 /s/ Elizabeth C. Brogan . 

 Elizabeth C. Brogan, Counsel for

 Suzanne E. Wade, Chapter 13 Trustee

CERTIFICATE OF SERVICE

I hereby certify a true copy of the foregoing NOTICE OF OBJECTION TO CONFIRMATION

was served electronically or by first-class mail, postage prepaid, this 4th day of March, 2020, upon the 

following parties:

Paul Richard Stewart

5854 Pilmour Drive 

Providence Forge, VA 23140

Patrick Thomas Keith, Counsel for Debtor

Boleman Law Firm, PC 

P.O. Box 11588 

Richmond, VA 23230-1588 

ecf@bolemanlaw.com

William R. Baldwin, III, Counsel for Donald R. Stewart

Meyer Baldwin Long & Moore LLP 

5600 Grove Avenue 

Richmond, VA 23226-2102 

billbaldwin@comcast.net

Brandon R. Jordan, Johnie Rush Muncy; Counsel for First Home Mortgage Corporation 

Samuel I. White, P.C. 

1804 Staples Mill Rd., Suite 200

Richmond, VA 23230 

bjordan@siwpc.com; jmuncy@siwpc.com

 /s/ Elizabeth C. Brogan . 

 Elizabeth C. Brogan, Counsel for

 Suzanne E. Wade, Chapter 13 Trustee