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UNITED STATES BANKRUPTCY COURT 

FOR THE EASTERN DISTRICT OF VIRGINIA 

Alexandria Division 

In the Matter of ) Chapter 13 

) 

SHIRLEY ANN GINWRIGHT ) Case No. 20-10872-KHK 

) 

Debtor ) 

NOTICE OF OBJECTION AND NOTICE OF HEARING

Oxford Station Townhouse Association, a secured creditor, by Counsel, has filed papers 

with the court objecting to Confirmation of the Chapter 13 Plan in the above captioned matter. 

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 motion (or objection), or if 

you want the court to consider your views on the motion (or objection), then you or your attorney 

must: 

 Attend the Plan Confirmation hearing scheduled to be held on June 1, 2020, at 1:30

p.m. at Judge Kindred’s Courtroom, 200 S. Washington Street, 3rd Floor, Courtroom

III, Alexandria, VA.

If you or your attorney do not take these steps, the court may decided that you do not 

oppose the relief sought in the motion and may enter an order granting that relief. 

Oxford Station Townhouse Association 

By Counsel: 

Dated: May 21, 2020 /s/ John R. Griffin 

John R. Griffin, VSB#71035 

john.griffin@griffinpllc.com 

P.O. Box 1295 

129 E. Davis Street, Suite 240 

Culpeper, VA 22701 

(571) 308-5820

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CERTIFICATE OF SERVICE

I hereby certify that on this 21st day of May, 2020, the following person(s) were or will 

be served with a copy of the foregoing Notice of Objection via the CM/ECF system or by first 

class mail, postage prepaid: 

Thomas P. Gorman, Trustee 

300 N. Washington Street, Suite 400 

Alexandria, VA 22314 

Barry Weintraub, Esquire 

2124 Jefferson Davis Hwy, Suite 201 

Stafford, VA 22556 

Shirley Ann Ginwright 

11615 Gunston Road 

Lorton, VA 22709 

/s/ John R. Griffin 

John R. Griffin, VSB#71035 

john.griffin@griffinpllc.com 

P.O. Box 1295 

129 E. Davis Street, Suite 240 

Culpeper, VA 22701 

(571) 308-5820

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UNITED STATES BANKRUPTCY COURT 

FOR THE EASTERN DISTRICT OF VIRGINIA 

Alexandria Division 

In the Matter of ) Case No. 20-10872 KHK 

) 

SHIRLEY ANN GINWRIGHT ) Chapter 13 

) 

Debtor ) 

OBJECTION TO CONFIRMATION OF DEBTOR’S PROPOSED CHAPTER 13 PLAN

Oxford Station Townhouse Association, a secured creditor, by Counsel, objects to the 

confirmation of Debtor’s proposed Chapter 13 Plan and states as follows: 

1. Oxford Station Townhouse Association (the “Association”) is a homeowner’s

association located in Stafford County, Virginia. 

2. On March 20, 2020, (the “Debtor”) filed a voluntary petition in this Court under

Chapter 13 of the United States Bankruptcy Code. 

3. Thomas P. Gorman is the Chapter 13 Trustee.

4. Debtor owns real property within the Association located at 1227 Thomas

Jefferson Place, Fredericksburg, VA 22405 (“the Property”). The Property is not Debtor’s 

principal residence. 

5. The Property is encumbered by three liens in favor of the Association as follows:

a. Memorandum of Lien dated 10/2/2015 in the amount of $2,414.96 and

recorded on 12/8/2015 as LR150021868 with the Clerk of the Circuit

Court for Stafford County, Virginia.

John R. Griffin, VSB#71035

P.O. Box 1295

129 E. Davis St., Suite 240

Culpeper, VA 22701

(571) 308-5820

Attorney for Oxford Station 

Townhouse Association

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b. Memorandum of Lien dated 8/27/2018 in the amount of $1,200.00 and

recorded at on 9/5/2018 as LR180015062 with the Clerk of the Circuit

Court for Stafford County, Virginia

c. Judgment entered on 8/27/2018 in the principal amount of $3,364.36,

court costs of $61.00, attorney’s fees of $800.00 and interest at 6% and

docketed with the Clerk of the Circuit Court for Stafford County, Virginia

on October 12, 2018 as Instrument Number 180005137 (hereinafter the

“Association Liens”).

6. On April 13, 2020, Debtor filed a Chapter 13 Plan and Related Motions. Under

section 7(b) of that Plan, Debtor proposes to avoid the Association Liens through adversary 

proceedings and claims the basis for avoidance is “Fair Debt Collection Act.” 

7. The Association assumes that Debtor’s reference to “Fair Debtor Collection Act”

refers to the Federal Fair Debt Collection Practices Act (FDCPA), 15 USC §1692. The FDCPA 

includes no provision that would allow a Debtor to invalidate a state issued judgment lien or a 

statutorily imposed lien in favor of a homeowner’s association. In addition, the Association is 

not a “Debt Collector” as that term is defined in 15 USC §1692a and the FDCPA does not apply 

to the Association. 

8. The hearing on confirmation of the Debtor’s proposed Plan is scheduled to take

place on June 1, 2020 at 1:30 p.m. 

WHEREFORE, the Association requests that this Court: 

1. Enter an order DENYING confirmation of the Debtor’s Chapter 13 Plan; and

2. Require Debtor to amend the Chapter 13 Plan within an imposed deadline to

reflect a proper treatment of the claim; and 

3. Grant such other and further relief as the nature of this matter may require.

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Oxford Station Townhouse Association 

By Counsel: 

Dated: May 21, 2020 /s/ John R. Griffin 

John R. Griffin, VSB#71035 

john.griffin@griffinpllc.com 

P.O. Box 1295 

129 E. Davis Street, Suite 240 

Culpeper, VA 22701 

(571) 308-5820

CERTIFICATE OF SERVICE

I hereby certify that on this 21st day of May, 2020, the following person(s) were or will 

be served with a copy of the foregoing Objection to Confirmation via the CM/ECF system or by 

first class mail, postage prepaid: 

Thomas P. Gorman, Trustee 

300 N. Washington Street, Suite 400 

Alexandria, VA 22314 

Barry Weintraub, Esquire 

2124 Jefferson Davis Hwy, Suite 201 

Stafford, VA 22556 

Shirley Ann Ginwright 

11615 Gunston Road 

Lorton, VA 22709 

/s/ John R. Griffin 

John R. Griffin, VSB#71035 

john.griffin@griffinpllc.com 

P.O. Box 1295 

129 E. Davis Street, Suite 240 

Culpeper, VA 22701 

(571) 308-5820

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