UNITED STATES BANKRUPTCY COURT 

FOR THE 

EASTERN DISTRICT OF VIRGINIA 

Alexandria Division 

In the Matter of: 

 Chapter 13

STACY LYNN PHILLIPS

 Case No. 21-10085-KHK

 Debtor

OBJECTION TO CONFIRMATION OF PLAN, 

NOTICE OF OBJECTION TO CONFIRMATION OF PLAN 

AND 

NOTICE OF SCHEDULED HEARING ON THIS OBJECTION 

Thomas P. Gorman, Chapter 13 Trustee, has filed this objection to confirmation of 

your Chapter 13 Plan filed January 21, 2021. The cause for this objection is as 

follows: 

Violation of 11 U.S.C. §1325(a)(6) - Feasibility. 

 Plan is predicated on successful lien strip based on highly speculative 

(service of process) grounds. 

 Debtor has not made her first Plan payment that was due on February 

20, 2021. 

Violation of 11 U.S.C. §1325(a)(4) - Liquidation Test. 

 Property would appear to have more net equity than Plan proposed to 

pay. 

Violation of 11 U.S.C. §1325(a)(6) - Feasibility. 

 Objection filed to preserve the rights of the Chapter 13 Trustee. The 

Section 341 Meeting of Creditors has been adjourned from 

 February 23, 2021 to March 9, 2021 at 11:30 A.M. 

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.) 

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Notice of Objection To Confirmation 

Stacy Lynn Phillips, Case # 21-10085-KHK 

If you do not wish 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 five business 

days prior to the hearing date, you or your attorney must: 

File with the court a written response with supporting memorandum as required 

by Local Bankruptcy Rule 9013-1(H). Unless a written response and 

supporting memorandum are filed and served by the date specified, the Court 

may deem any opposition waived, treat the motion as conceded, and issue an 

order granting the requested relief without further notice or hearing. If you mail 

your 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. You must mail a copy to the 

persons listed below. 

Attend the hearing to be held on March 25, 2021 at 1:30 p.m., in Courtroom 

III on the 3rd floor, United States Bankruptcy Court, 200 South Washington 

Street, Alexandria, VA 22314.1 If no timely response has been filed opposing 

the relief requested, the court may grant the relief without holding a hearing. 

 A copy of any written response must be mailed to the following persons: 

 Thomas P. Gorman 

 300 North Washington Street, Ste, 400 

 Alexandria, VA 22314 

 Clerk of the Court 

 United States Bankruptcy Court 

200 South Washington Street 

Alexandria, VA 22314 

1 Pursuant to the Bankruptcy Court’s Protocol in response to COVID-19 Public Health 

Emergency, parties appearing for hearings shall appear via Zoom for Government and 

must pre-register and follow the procedures set forth at 

https://www.vaeb.uscourts.gov/wordpress/?page_id=9098. 

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Notice of Objection To Confirmation 

Stacy Lynn Phillips, Case # 21-10085-KHK 

 If you or your attorney do not take 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. 

Date: _February 26, 2021______ __/s/Thomas P. Gorman ________

 Thomas P. Gorman 

 Chapter 13 Trustee 

 300 N. Washington Street, #400 

 Alexandria, VA 22314 

 (703) 836-2226 

 VSB 26421 

CERTIFICATE OF SERVICE 

I hereby certify that I have this 26th day of February, 2021, served via ECF to 

authorized users or mailed a true copy of the foregoing Objection to Confirmation, 

Notice of Objection and Notice of Hearing to the following parties. 

Stacy Lynn Phillips 

Chapter 13 Debtor 

5267 Quebec Place 

Woodbridge, VA 22193 

Martin C. Conway 

Attorney for Debtor 

Conway Law Group, PC 

12934 Harbor Drive, Suite 107 

Woodbridge, VA 22192 

 __/s/ Thomas P. Gorman______ 

 Thomas P. Gorman

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