United States Bankruptcy Court 

Eastern District of Virginia 

Richmond Division 

In RE: 

Katina Lashawn McMahand 

Debtor

BCN#: 19-36671-KRH 

Chapter: 13 

U.S. Bank National Association, as Trustee 

for MASTR Asset Backed Securities Trust 

2006-NC3 Mortgage Pass-Through 

Certificates, Series 2006-NC3 

or present noteholder, 

Movant/Secured Creditor,

v. 

Katina Lashawn McMahand 

Debtor 

RESPONSE TO DEBTOR’S MOTION TO SELL REAL ESTATE 

Comes now U.S. Bank National Association, as Trustee for MASTR Asset Backed Securities 

Trust 2006-NC3 Mortgage Pass-Through Certificates, Series 2006-NC3 (“Creditor”), by Counsel, 

and for its response to the Debtor's Motion to Sell Real Property states as follows: 

1. That U.S. Bank National Association, as Trustee for MASTR Asset Backed Securities 

Trust 2006-NC3 Mortgage Pass-Through Certificates, Series 2006-NC3 holds a first priority deed of 

trust secured by real property located at 1426 Lynhaven Avenue, Richmond, VA 23224. 

2. That Creditor consents to the sale of the real property located at 1426 Lynhaven 

Avenue, Richmond, VA 23224, which is secured by a deed of trust held by U.S. Bank National 

Association, as Trustee for MASTR Asset Backed Securities Trust 2006-NC3 Mortgage PassThrough Certificates, Series 2006-NC3, provided that there are sufficient proceeds to pay its 

underlying note and deed of trust in full through settlement. 

Case 19-36671-KRH Doc 60 Filed 12/01/21 Entered 12/01/21 11:04:42 Desc Main

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3. Further, that Creditor requests that all proceeds from the sale of the property be used 

to pay U.S. Bank National Association, as Trustee for MASTR Asset Backed Securities Trust 2006-

NC3 Mortgage Pass-Through Certificates, Series 2006-NC3 in full, including its outstanding fees and 

costs due and owing at the date of settlement. Nothing contained herein shall prevent the Secured 

Creditor from proceeding to foreclosure upon obtaining relief from the Automatic Stay. 

4. To the extent that the proceeds of the sale are insufficient to pay its underlying note 

and deed of trust in full including its fees and costs at settlement, then U.S. Bank National Association, 

as Trustee for MASTR Asset Backed Securities Trust 2006-NC3 Mortgage Pass-Through 

Certificates, Series 2006-NC3 is opposed to the Motion to Sell Real Property. 

Dated: 12/01/2021 

LOGS LEGAL GROUP LLP 

Attorneys for U.S. Bank National 

Association, as Trustee for MASTR Asset 

Backed Securities Trust 2006-NC3 Mortgage 

Pass-Through Certificates, Series 2006-NC3 

 /s/ Mary F. Balthasar Lake 

By: _________________________ 

Malcolm B. Savage, III, Esquire 

VSB #91050 

William M. Savage, Esquire 

VSB #26155 

Mary F. Balthasar Lake, Esquire 

VSB #34899 

Gregory N. Britto, Esquire 

VSB #23476 

Randa Azzam, Esquire 

VSB #31539 

Counsel for Movant 

Case 19-36671-KRH Doc 60 Filed 12/01/21 Entered 12/01/21 11:04:42 Desc Main

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CERTIFICATE OF SERVICE 

I hereby certify that on the 1st day of December, 2021 the following person(s) were served a copy 

of the foregoing in the manner described below: 

Via CM/ECF Electronic Notice: 

James E. Kane Debtor’s Attorney 

Kane & Papa, PC 

1313 East Cary Street 

P.O. Box 508 

Richmond, VA 23218-0508 

Carl M. Bates 

P. O. Box 1819 

Richmond, VA 23218

Chapter 13 Trustee 

Via First Class Mail, Postage Prepaid: 

Katina Lashawn McMahand 

1426 Lynhaven Ave 

Richmond, VA 23224 

Debtor(s) 

 /s/ Mary F. Balthasar Lake 

_____________________________ 

Malcolm B. Savage, III, Esquire 

VSB #91050 

William M. Savage, Esquire 

VSB #26155 

Mary F. Balthasar Lake, Esquire 

VSB #34899 

Gregory N. Britto, Esquire 

VSB #23476 

Randa Azzam, Esquire 

VSB #31539 

LOGS LEGAL GROUP LLP 

10021 Balls Ford Road, Suite 200 

Manassas, Virginia 20109 

(703) 449-5800 

logsecf@logs.com 20-285789 

Case 19-36671-KRH Doc 60 Filed 12/01/21 Entered 12/01/21 11:04:42 Desc Main

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