IN THE UNITED STATES BANKRUPTCY COURT 

FOR THE EASTERN DISTRICT OF VIRGINIA 

Richmond Division 

 

IN RE: ) 

 ) 

JAMES HENRY HAWKINS ) Case No. 20-30048-KLP 

 ) Chapter 13 

 ) Trustee: Carl M. Bates 

 Debtor ) 

 

NOTICE OF APPLICATION BY 

KANE & PAPA, P.C. FOR SUPPLEMENTAL COMPENSATION 

Kane & Papa, P.C., counsel for the above debtor has filed a Supplemental Application for 

Allowance of Compensation pursuant to 11 U.S.C. §§ 330(a) and 503(b)(2) and Federal Rules of 

Bankruptcy Procedure 2016. 

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 application, or if you want the court 

to consider your views on the application, then, within fourteen (14) days from the date of this 

Notice you or your attorney must: 

 File with the court, at the address shown below, a written request for a hearing [or 

written response pursuant to Local Bankruptcy Rule 9013-1(H)]. If you mail your 

request for a hearing (or 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, to: 

Clerk of Court 

United States Bankruptcy Court 

701 East Broad Street, Suite 4000 

Richmond, VA 23219 

You must also mail a copy to: 

James E. Kane, Esquire 

KANE & PAPA, P.C. 

P.O. Box 508 

Richmond, Virginia 23218-0508 

Case 20-30048-KLP Doc 30 Filed 05/15/20 Entered 05/15/20 15:33:16 Desc Main

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 Attend the hearing scheduled for June 3, 2020 at 10:00 a.m. at 701 East Broad 

Street, Room 5100, Richmond, VA 23219. If no timely response has been 

filed, the Court may grant the relief sought in the application without a hearing. 

If you or your attorney do not take these steps, the Court may decide that you do not oppose the 

relief sought in the Application and may enter an Order granting relief sought in the application, 

and may enter an Order granting that relief without a hearing. 

Dated: May 15, 2020 KANE & PAPA P.C.

 

By: /s/ James E. Kane 

James E. Kane (VSB #30081) 

KANE & PAPA, P.C. 

P.O. Box 508 

Richmond, VA 23218-0508 

(804) 225-9500 (phone) 

(804) 225-9598 (fax) 

Counsel for Debtor

CERTIFICATE OF SERVICE 

I certify that on May 15, 2020, I have transmitted a true copy of the foregoing document 

electronically through the court’s CM/ECF system or by mail to the debtor, chapter 13 trustee, 

the United States trustee if other than by the electronic means provided for at Local Bankruptcy 

Rule 2002-1, and to all necessary parties as listed on the matrix attached herewith. 

 /s/ James E. Kane 

James E. Kane 

Counsel for Debtor 

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IN THE UNITED STATES BANKRUPTCY COURT 

FOR THE EASTERN DISTRICT OF VIRGINIA 

Richmond Division 

 

IN RE: ) 

 ) 

JAMES HENRY HAWKINS ) Case No. 20-30048-KLP 

 ) Chapter 13 

 ) Trustee: Suzanne E. Wade 

 Debtor ) 

 

APPLICATION BY KANE & PAPA, P.C. 

FOR SUPPLEMENTAL COMPENSATION 

COMES NOW, Kane & Papa P.C., counsel for debtor, and pursuant to 11 U.S.C. 

§§ 330(a), 331(b)(2), and 503(b)(2) and Federal Rules of Bankruptcy Procedure 2016, 

respectfully applies to the Honorable Court for approval and payment of supplemental fees in the 

amount of $1,754.50 which includes attorney fees of $1,754.00 and costs of $4.50. 

1. The period covered by this application is for additional work not included in the initial 

“no-look” fees through the date of this Application. 

2. Fees in the amount of $5,434.00 have either been previously paid by the debtor or 

approved for payment through the Chapter 13 Plan. 

3. James E. Kane was admitted to practice law in 1989 and has been practicing for 30 years. 

The hourly rate charged by James E. Kane is $350.00 per hour for attorney time. 

4. Pursuant to Bankruptcy Rule 2016(b), a Disclosure of Compensation of Attorney for 

Debtor(s) has been filed in this case and Notice of Filing of Rule 2016-1 Disclosure of 

Compensation was served on the Debtor and the Standing Trustee pursuant to LBR 2016. 

No objection to the compensation requested in the Disclosure Statement has been filed by 

either the Standing Trustee or the Debtor. 

James E. Kane (VSB #30081) 

KANE & PAPA, P.C. 

P.O. Box 508 

Richmond, VA 23218-0508 

(804) 225-9500 (phone) 

(804) 225-9598 (fax) 

Counsel for Debtor

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5. Supplemental Compensation is requested for time and costs related to the following 

services: 

Professional services rendered to the debtor in connection with the preparation and 

filing of an Adversary Proceeding to Determine Validity, Extent and Priority of 

Lien pursuant to 11 U.S.C. § 506(a) filed on January 20, 2020, resulting in a 

judgments in favor of Debtor entered by the Court on April 1, 2020 and May 12, 

2020. 

6. Charges have not been included for the preparation and cost for noticing of the fee 

application and any court appearances related to the application. An itemized statement 

of services and fees is attached hereto as Exhibit “A” and is incorporated herein by this 

reference. 

7. James E. Kane has reviewed the Debtor’s budget and believes that the Chapter 13 Plan 

provides sufficient reserves or may be extended in time so that payments requested herein 

may be made without prejudice to any creditor. Upon information and belief, payment of 

the requested compensation will not reduce the dividend to unsecured creditors as 

provided in the most recently confirmed Chapter 13 Plan. 

WHEREFORE, Kane & Papa P.C., respectfully requests this Honorable Court to approve 

supplemental fees in the amount of $1,754.50 to be paid through the Chapter 13 plan as an 

administrative expense claim pursuant to 11 U.S.C. 503. 

Respectfully submitted, 

KANE & PAPA P.C.

 

By: /s/ James E. Kane 

James E. Kane (VSB #30081) 

KANE & PAPA, P.C. 

P.O. Box 508 

Richmond, VA 23218-0508 

(804) 225-9500 (phone) 

(804) 225-9598 (fax) 

Counsel for Debtor

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CERTIFICATE OF SERVICE 

I certify that on May 15, 2020, I have transmitted a true copy of the foregoing document 

electronically through the Court’s CM/ECF system or by mail to the debtors, chapter 13 trustee, 

the United States trustee if other than by the electronic means provided for at Local Bankruptcy 

Rule 2002-1, and to all necessary parties, as listed on the matrix attached herewith. 

 /s/ James E. Kane 

 James E. Kane 

 Counsel for Debtor 

 

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Kane & Papa, P.C.

PO BOX 508

RICHMOND, VA 23218 US

804-225-9500

jkane@kaneandpapa.com

INVOICE

BILL TO

James Hawkins

6819 Silliman Drive

Chesterfield, VA 23832

INVOICE # 5998

DATE 05/15/2020

DUE DATE 06/01/2020

TERMS Due on receipt

 

DATE ACTIVITY QTY RATE AMOUNT

01/20/2020 Consulting:Legal

Review property valuation on 6819 

Silliman Drive, Chesterfield, VA from, 

tax assessment; review first and second 

DOTs and, balances with U.S. National 

Bank/Select Portfolio Servicing, Inc.; 

review judgment and lien by Western 

Development, LLC; review judgment 

and lien by Joseph Jenkins, Jr. Funeral 

Home, Inc.

1.10 350.00 385.00

01/20/2020 Consulting:Legal

Prepare Complaint against Western 

Development, LLC and Joseph Jenkins, 

Jr. Funeral Home, Inc. and file with the 

Court

1.30 350.00 455.00

01/22/2020 Consulting:Legal

Review Summons and serve Summons 

and Complaint on Western 

Development, LLC and Joseph Jenkins, 

Jr. Funeral Home, Inc. and and file 

certificate of service

and file with court

0.30 350.00 105.00

01/22/2020 Postage and Delivery

Postage and Copy Charges

2.50 2.50

03/23/2020 Consulting:Legal

Review Motion of Western Development 

to Extend Time to File Answer; review 

Answer of Western Development

0.20 350.00 70.00

03/27/2020 Consulting:Legal

Negotiate settlement with counsel for 

Western Development; review Consent 

Order prepared by counsel for Western 

Development, LLC and approve the 

same

0.50 350.00 175.00

03/31/2020 Consulting:Legal 1.20 350.00 420.00

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DATE ACTIVITY QTY RATE AMOUNT

Prepare Motion for Entry of Default and 

Default Judgment against Joseph 

Jenkins, Jr. Funeral Home, Inc. and file 

with the Court and serve on defendant

03/31/2020 Postage and Delivery

Postage and Copy Charges

2.00

05/08/2020 Consulting:Legal

Prepare Order Granting Default 

Judgment against Joseph Jenkins, Jr. 

Funeral Home, Inc. and submit to Court 

for entry

0.40 350.00 140.00

Hawkins v. Western Development, LLC and Joseph Jenkins, Jr. Funeral 

Home, Inc.

BALANCE DUE $1,754.50

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 Label Matrix for local noticing U.S. Bank, N.A., successor trustee to LaSall UST smg Richmond 

 0422-3 c/o Shapiro & Brown, LLP. Office of the U. S. Trustee 

 Case 20-30048-KLP 501 Independence Parkway 701 East Broad St., Suite 4304 

 Eastern District of Virginia Suite 203 Richmond, VA 23219-1849 

 Richmond Chesapeake, Va 23320-5174 

 Fri May 15 15:29:56 EDT 2020 

 United States Bankruptcy Court Ballato Law Firm Credit Acceptance 

 701 East Broad Street 3721 Westerre Parkway 25505 West 12 Mile Rd 

 Richmond, VA 23219-1888 Suite A Suite 3000 

 Henrico, VA 23233-1332 Southfield, MI 48034-8331 

 

 (p)JEFFERSON CAPITAL SYSTEMS LLC Joseph Jenkins Funeral Home Mrs. Haeja O. Namkoong 

 PO BOX 7999 2011 Grayland Ave 8651 Nesslewood Rd 

 SAINT CLOUD MN 56302-7999 Richmond, VA 23220-5807 Henrico, VA 23229-3170 

 Select Portfolio Servicing, Inc Select Portfolio Servicing, Inc. T Mobile/T-Mobile USA Inc 

 Attn: Bankruptcy P.O. Box 65250 by American InfoSource as agent 

 Po Box 65250 Salt Lake City, UT 84165-0250 4515 N Santa Fe Ave 

 Salt Lake City, UT 84165-0250 Oklahoma City, OK 73118-7901 

 Verizon Verizon WESTERN DEVELOPMENT, LLC 

 P.O. Box 660720 by American InfoSource as agent GOODWIN-JONES & PRICE, PC 

 Dallas, TX 75266-0720 4515 N Santa Fe Ave 20 S. AUBURN AVE. 

 Oklahoma City, OK 73118-7901 RICHMOND, VA 23221-2910 

 Western Development, LLC Westviewfnsv James E. Kane 

 3610 South Place 1068 Temple Ave Kane & Papa, PC 

 Alexandria, VA 22309-2201 Colonial Heights, VA 23834-2981 1313 East Cary Street 

 P.O. Box 508 

 Richmond, VA 23218-0508 

 

 James Henry Hawkins John P. Fitzgerald, III Suzanne E. Wade 

 6819 Silliman Drive Office of the US Trustee - Region 4 -R 341 Dial 877-996-8484 Code 2385911 

 Chesterfield, VA 23832-8340 701 E. Broad Street, Ste. 4304 7202 Glen Forest Drive, Ste. 202 

 Richmond, VA 23219-1849 Richmond, VA 23226-3770 

 The preferred mailing address (p) above has been substituted for the following entity/entities as so specified 

 by said entity/entities in a Notice of Address filed pursuant to 11 U.S.C. 342(f) and Fed.R.Bank.P. 2002 (g)(4). 

 Jefferson Capital Systems LLC 

 Po Box 7999 

 Saint Cloud Mn 56302-9617 

 The following recipients may be/have been bypassed for notice due to an undeliverable (u) or duplicate (d) address. 

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 (u)Mrs. Lee (d)Western Development, LLC End of Label Matrix 

 3610 South Place Mailable recipients 20 

 Alexandria, VA 22309-2201 Bypassed recipients 2 

 Total 22 

 

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