UNITED STATES BANKRUPTCY COURT 

FOR THE 

EASTERN DISTRICT OF VIRGINIA 

Alexandria Division 

In the Matter of: 

 Chapter 13

ANA MARIAM BEJARANO

 Case No. 21-10087-KHK

 Debtor

OBJECTION TO CONFIRMATION OF MODIFIED PLAN, 

NOTICE OF OBJECTION TO CONFIRMATION OF MODIFIED PLAN 

AND 

NOTICE OF SCHEDULED HEARING ON THIS OBJECTION 

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

your Modified Chapter 13 Plan filed August 19, 2021. The cause for this objection is 

as follows: 

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

 Debtor was unable to maintain her Plan obligations in her most recent 

prior case, (Case No. 18-13444-BFK) which was dismissed less than 

two months before this one was filed. Her financial situation does not 

seem to have materially changed. 

 Plan does not provided for filed priority Proof of Claim of Virginia 

Department of Taxation (Claim #18). 

Violation of 11 U.S.C. §1325(a)(3) and 11 U.S.C. §1325(b)(1)(B) - Good 

Faith and Disposable Income. 

 Trustee objects to payment of mother's vehicle1

 on a 34% Plan. 

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.) 

 

1

 Section 4D of this Plan refers to this as “Husband’s Auto”, which is revisionist. It was previously 

described as their “Mother’s Auto”. (See Plan filed April 15, 2021, Dkt #33, Section 4D) 

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Document Page 1 of 3
Notice of Objection To Confirmation 

Ana Mariam Bejarano, Case # 21-10087-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. 

REMOTE HEARING INFORMATION:

Due to the COVID-19 public health emergency, no in-person hearings are being held. 

This hearing will take place remotely through Zoom on the date and time scheduled 

herein. 

To appear at the hearing, you must send, by email, a completed request form (the 

“Zoom Request Form”), which is available on the Court’s internet website at 

www.vaeb.courts.gov, on the page titled, “Temporary Emergency Provisions 

Regarding ZoomGov Remote Proceeding Access Information.” Email your completed 

Zoom Request Form to the email address listed for the Judge assigned to the case. 

Following receipt of your Zoom Request Form, Court staff will respond to the email 

address from which the request was submitted with additional information on how to 

participate through Zoom. 

*** The email address shall be used only to submit Zoom Request Forms. No other 

matters or requests will be considered by Court staff, and under no circumstances will 

any such matters or requests be brought to the Judge’s attention. Failure to comply 

with these instructions may result in appropriate action, including but not limited to the 

imposition of sanctions. *** 

PLEASE NOTE: You MUST submit the Zoom Request Form no later than two (2) 

business days prior to this hearing. Any documentary evidence the parties wish to 

present at the hearing must be filed with the Court in advance of the hearing. 

Attend the hearing to be held on September 23, 2021 at 1:30 p.m., in 

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

Washington Street, Alexandria, VA 22314. If no timely response has been 

filed opposing the relief requested, the court may grant the relief without 

holding a hearing. 

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Notice of Objection To Confirmation 

Ana Mariam Bejarano, Case # 21-10087-KHK 

 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 

 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: _August 24, 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 24th day of August, 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. 

Ana Mariam Bejarano 

Chapter 13 Debtor 

4204 Carmel Terrace 

Chantilly, VA 20151 

Suad Bektic 

Attorney for Debtor 

New Day Legal, PLLC 

98 Alexandria Pike, Suite 10 

Warrenton, VA 20186 

 __/s/ Thomas P. Gorman______ 

 Thomas P. Gorman

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