UNITED STATES BANKRUPTCY COURT

EASTERN DISTRICT OF VIRGINIA

ALEXANDRIA DIVISION

In re:

DEBRA F. REID,

Address: 11009 Fairchester Dr.

Fairfax, VA 22030

CASE NO: 17-12923-KHK

CHAPTER 7

Debtor(s)

U.S. BANK TRUST, N.A., AS TRUSTEE FOR 

LSF9 MASTER PARTICIPATION TRUST

Plaintiff,

v.

DEBRA F. REID,

Debtor(s)

DONALD F. KING, Trustee

 Defendants.

NOTICE OF MOTION FOR RELIEF FROM THE AUTOMATIC STAY 

 U.S. Bank Trust, N.A., as Trustee for LSF9 Master Participation Trust, a creditor in this case, 

has filed papers with the court to obtain relief from the automatic stay of the Bankruptcy Code with 

regard to certain property more particularly described in those papers which are attached. 

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 wish the Court to grant the relief sought in the 

motion, or if you want the court to consider your views on the motion, then within 14 days 

from the date of service of this motion, you must file a written response explaining your 

position with the Court and serve a copy on the movant. Unless a written response is filed and 

served within this 14-day period, the Court may deem 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 expiration of the 14-day period. You will be notified separately of 

the hearing date on the motion. 

If you do not want the Court to grant this creditor relief from the provisions of the automatic 

stay of the Bankruptcy Code, or if you want the Court to consider your views on the Motion for relief 

from the automatic stay, then on or before October 18, 2017, you or your attorney must: 

Case 17-12923-KHK Doc 19 Filed 10/04/17 Entered 10/04/17 16:58:01 Desc Main

 Document Page 1 of 24
File with the Court, at the address shown below, a written response pursuant to Local 

Bankruptcy Rules 4001(a)-1(C) and 9013-1(H). 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.

United States Bankruptcy Court

200 South Washington Street

Alexandria, VA 22314

You must also mail a copy of any such response to: 

 M. Christine Maggard, Esquire 

 Brock & Scott, PLLC 

 484 Viking Dr., Ste 203 

 Virginia Beach, VA 23452 

Attend the preliminary hearing that will be conducted in the Alexandria Division of the US 

Bankruptcy Court, 200 South Washington Street, Alexandria, VA 22314 on November 15, 2017 

at 9:30 AM in Courtroom II, second floor. 

If no timely response has been filed opposing the relief requested, the Court may grant the relief 

requested in the Motion from Relief from Stay. 

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 for Relief from Automatic Stay and may enter an Order granting the relief. 

Date: October 4, 2017 Signature: /s/M. Christine Maggard 

 Name: M. Christine Maggard, VSB# 33824 

 Brock & Scott, PLLC 

 484 Viking Dr. Ste 203 

 Virginia Beach, VA 23452 

Case 17-12923-KHK Doc 19 Filed 10/04/17 Entered 10/04/17 16:58:01 Desc Main

 Document Page 2 of 24
CERTIFICATE OF SERVICE

/s/ M. Christine Maggard

M. Christine Maggard, VSB# 33824

Brock & Scott, PLLC

484 Viking Dr., Ste 203

Virginia Beach, VA 23452

I hereby certify that on October 4, 2017, a true copy of the foregoing Notice of Motion for 

Relief from the Automatic Stay was submitted for electronic transmittal or mailed, first class, 

postage prepaid to: 

Brian Kenneth Madden 

PO Box 7663 

Arlington, VA 22207 

Donald F. King 

1775 Wiehle Avenue, Suite 400 

Reston, VA 20190 

Debra F. Reid 

11009 Fairchester Dr. 

Fairfax, VA 22030 

Case 17-12923-KHK Doc 19 Filed 10/04/17 Entered 10/04/17 16:58:01 Desc Main

 Document Page 3 of 24
UNITED STATES BANKRUPTCY COURT

EASTERN DISTRICT OF VIRGINIA

ALEXANDRIA DIVISION

In re:

DEBRA F. REID,

Address: 11009 Fairchester Dr.

Fairfax, VA 22030

CASE NO: 17-12923-KHK

CHAPTER 7

Debtor(s)

U.S. BANK TRUST, N.A., AS TRUSTEE FOR 

LSF9 MASTER PARTICIPATION TRUST

Plaintiff,

v.

DEBRA F. REID,

Debtor(s)

DONALD F. KING, Trustee

 Defendants.

MOTION FOR RELIEF FROM AUTOMATIC STAY 

TO ALL DEFENDANTS:

 Pursuant to Rule 4001(a)-1(C) of the Local Rules of the United States Bankruptcy 

Court of the Eastern District of Virginia, you have fourteen (14) days from October 4, 

2017, the date of service of this Motion upon you, to file a written response thereto and you 

must file such response with the Clerk of the United States Bankruptcy Court, Alexandria 

Division, 200 South Washington Street, Alexandria, VA 22314 and serve a copy of same upon 

the Plaintiff’s attorney, M. Christine Maggard, at 484 Viking Dr. Suite 203, Virginia Beach, 

VA 23452.

M. Christine Maggard, VSB# 33824 

Brock & Scott, PLLC 

484 Viking Dr., Ste 203 

Virginia Beach, VA 23452 

757-213-2959 Ext. 4538 (paralegal) 

vaecf@brockandscott.com

Attorney for U.S. Bank Trust, N.A., as Trustee for LSF9 Master Participation Trust. 

TO THE HONORABLE KLINETTE H KINDRED: 

Case 17-12923-KHK Doc 19 Filed 10/04/17 Entered 10/04/17 16:58:01 Desc Main

 Document Page 4 of 24
Your Plaintiff, U.S. Bank Trust, N.A., as Trustee for LSF9 Master Participation Trust, 

respectfully represents as follows:

1. That this is a core proceeding within the meaning of the Bankruptcy Code and Rules.

2. That on August 29, 2017, the above-named Debtors filed a Petition in this Court.

3. That Donald F. King was appointed Trustee of the property, has qualified and is now acting.

4. That at the time of the filing of the Debtor’s petition herein, the Debtor had an ownership 

interest in certain real property and improvements having a street address of 11009 

Fairchester Drive, Fairfax, VA 22030, and more particularly described as follows:

5. That the Plaintiff is the holder of a Note dated August 5, 2011, in the original principal 

amount of $116,100.00 with interest thereon from said date at the rate of 4.875% per annum, 

secured by a Deed of Trust on said real property and improvements recorded in the Clerk’s 

Office of the Circuit Court of the County of Fairfax City, Virginia, on which there is an 

approximate payoff balance of $149,275.53 as of September 8, 2017. True copies of the Note 

and Deed of Trust are attached hereto and incorporated by reference as Exhibits “A” and “B”, 

respectively.

6. That the Debtor has defaulted in the payments due to Plaintiff relative to the aforementioned 

Note.

7. That the Debtors, upon information and belief, do not wish to retain possession of the 

Case 17-12923-KHK Doc 19 Filed 10/04/17 Entered 10/04/17 16:58:01 Desc Main

 Document Page 5 of 24
aforesaid real property and, accordingly, have provided for the surrender of same in the 

Debtor’s Statement of Intentions. That in order to institute state foreclosure proceedings 

relative to the aforesaid real property and improvements, the Plaintiff is required to be 

relieved from the provision of the automatic stay of the Bankruptcy Code which presently 

prohibit such foreclosure.

8. That in the event the Plaintiff is granted relief from stay hereunder, the Plaintiff, its agents 

and/or representatives, requests that the Order granting said relief allow the Plaintiff, its 

agents and/or representatives, to send communications, as necessary, to the Debtor, 

including, but not limited to, notices required by applicable state law in connection with 

applicable State Court foreclosure or other proceedings incident to the aforesaid real property 

and improvements including and proceedings necessary to recover possession of same from 

the Debtors.

9. That the facts hereinabove alleged constitute cause for a grant of stay relief in favor of the 

Plaintiff pursuant to the provisions of 11 USC §362(d).

WHEREFORE, Plaintiff prays that it be granted relief from the provisions of the automatic stay of 

the Bankruptcy Code with regard to the above-described real property and improvements including 

any act necessary to recover possession of same from the Debtor and that the stay of such grant of 

relief imposed pursuant to the provisions of Rule 4001(a)(3) of the Bankruptcy Rules be waived. 

That Creditor be entitled to recover its reasonable fees and expenses incurred in connection with 

seeking the relief requested in this Motion.

U.S. Bank Trust, N.A., as Trustee for LSF9 

Master Participation Trust

By: /s/M. Christine Maggard

Of Counsel

Case 17-12923-KHK Doc 19 Filed 10/04/17 Entered 10/04/17 16:58:01 Desc Main

 Document Page 6 of 24
CERTIFICATE OF SERVICE

/s/ M. Christine Maggard

M. Christine Maggard, VSB# 33824

Brock & Scott, PLLC

484 Viking Dr., Ste 203

Virginia Beach, VA 23452

I hereby certify that on october 4, 2017, a true copy of the foregoing Motion for Relief from the 

Automatic Stay was submitted for electronic transmittal or mailed, first class, postage prepaid to: 

Brian Kenneth Madden 

PO Box 7663 

Arlington, VA 22207 

Donald F. King 

1775 Wiehle Avenue, Suite 400 

Reston, VA 20190 

Debra F. Reid 

11009 Fairchester Dr. 

Fairfax, VA 22030 

Case 17-12923-KHK Doc 19 Filed 10/04/17 Entered 10/04/17 16:58:01 Desc Main

 Document Page 7 of 24
E 


1 X 

] ] 


7


]


S E O Y 


s


K F N A . 


T 


.


.


S 


I 1 e y y t n T 

"


1 e y y s t


P O . x 0 , s , X 5 0 


.


s 


Y 


.


S 


d d 

t


r


f


t 


A


) 

F 


: 


. 


L 


p 


3 


i 

Case 17-12923-KHK Doc 19 Filed 10/04/17 Entered 10/04/17 16:58:01 Desc Main

 Document Page 8 of 24
Case 17-12923-KHK Doc 19 Filed 10/04/17 Entered 10/04/17 16:58:01 Desc Main

 Document Page 9 of 24
Case 17-12923-KHK Doc 19 Filed 10/04/17 Entered 10/04/17 16:58:01 Desc Main

 Document Page 10 of 24
Case 17-12923-KHK Doc 19 Filed 10/04/17 Entered 10/04/17 16:58:01 Desc Main

 Document Page 11 of 24
Case 17-12923-KHK Doc 19 Filed 10/04/17 Entered 10/04/17 16:58:01 Desc Main

 Document Page 12 of 24
Case 17-12923-KHK Doc 19 Filed 10/04/17 Entered 10/04/17 16:58:01 Desc Main

 Document Page 13 of 24
Case 17-12923-KHK Doc 19 Filed 10/04/17 Entered 10/04/17 16:58:01 Desc Main

 Document Page 14 of 24
Case 17-12923-KHK Doc 19 Filed 10/04/17 Entered 10/04/17 16:58:01 Desc Main

 Document Page 15 of 24
Case 17-12923-KHK Doc 19 Filed 10/04/17 Entered 10/04/17 16:58:01 Desc Main

 Document Page 16 of 24
Case 17-12923-KHK Doc 19 Filed 10/04/17 Entered 10/04/17 16:58:01 Desc Main

 Document Page 17 of 24
Case 17-12923-KHK Doc 19 Filed 10/04/17 Entered 10/04/17 16:58:01 Desc Main

 Document Page 18 of 24
Case 17-12923-KHK Doc 19 Filed 10/04/17 Entered 10/04/17 16:58:01 Desc Main

 Document Page 19 of 24
Case 17-12923-KHK Doc 19 Filed 10/04/17 Entered 10/04/17 16:58:01 Desc Main

 Document Page 20 of 24
Case 17-12923-KHK Doc 19 Filed 10/04/17 Entered 10/04/17 16:58:01 Desc Main

 Document Page 21 of 24
0


0


s


i


)


)


d


r r 

1 e 

R 


d O 

2 


Case 17-12923-KHK Doc 19 Filed 10/04/17 Entered 10/04/17 16:58:01 Desc Main

 Document Page 22 of 24
2 


: 


.


' 
 X , A 0


I 

y 

1


6 


Z 


~ 


3


Case 17-12923-KHK Doc 19 Filed 10/04/17 Entered 10/04/17 16:58:01 Desc Main

 Document Page 23 of 24
2017009524.001 8K249421506 O2lO9l2O17 1O'.51:20

Recording Requested By:

Prepared By:

Caliber Horrre Loans, Inc.

13801 Wireless Woy

Oklahoma City, OK 73134

(45) 6ot-2535,J DrvYA SREE

And When Recorded Mail To:

Callber Home l-oans, fnc.

13801 Wirelcs Way

Oklahoma Clty, OK 73f34

(405) 608-2535

TAX ID e2

ASSIGNMENT OF DEED OF TRUST

FOR VALUE RECEIVED, FEDERALNATIONAL MORTGAGE ASSOCIATION, 39OO WISCONSIN

AVENIIE' NW' WASHINGTON' DC 20016-0000, hereby assign and transfer to U.S. BANK TRUST, N.A.,

AS TRUSTEE FOR LSFS MASTER PARTICIPA'r'IoN TRUSI., 13801 WIRELESS WAy, OKLAHOMA

CITY' OK 73134-0000, all its right, title and inlerest in aud to said Deed of Trust in the amount of $116.100.00.

recorded in the State of VIRGINIA, County of FAIRFAX Official Records, dated AUGUST 05.201f recorded

on AUGUST l61 2011, as lustrument No. 2011030973.001, In Book No. 2180t, et Page No. 0140.

Executed by: DEBRA FAY REID, UNMARRIED (Original Morrgagor).

original Mortgagee: BAIYK oF AMERTCA, N.A.. original Trustee: sAMrJEf, r. wHrrE, p.c..

Date: JANUARY 19,2017

FEDERAL NATIONAL MORTGAGI!, AssoclATIoN, By CALIBER HOME LoAI\s. INc. As

ATTORNEY IN FACT

Roy Lacey, 

4A

Authorized Signatory

State of OKLAIIOMA )

Count5r of OKLAHOMA ) ss.

on JAIIUARY l9'2O17 , before me, Nancy Ortlz, a Notary Public, personally appeared Roy Lecey , who

proved to me on the basis of satisfactory evidencr to be the person(s) whose name(s) iVare subscribed to the

withiu instrument aud acknowledged to me that he/she/they executed the same in his/her/their authorized

oapocity(ies) and that by his/hcr/their siFaturc(s) on the instrument tle person(s), or the entity upon behalf of

which the person(s) acted, executed the instrument.

Witness rny hand and official seal.

By

Space above for Recorder,s use

custo.rer#: r/1 serv fllllllllllllll

Loan#

o2to9t2017

E@toaoi&tAt6vA **/L 7 -/*r-

/ 

SL.RK (/

Nanre)'! Nency Ortlz =,,.ffi...-.k

TAX ID# 

Case 17-12923-KHK Doc 19 Filed 10/04/17 Entered 10/04/17 16:58:01 Desc Main

 Document Page 24 of 24