Bradley Jones (VSB No. 85095) 

Counsel for the `Trustee

ODIN FELDMAN & PITTLEMAN PC

1775 Wiehle Avenue, Suite 400

Reston, Virginia 20190

Phone: 703-218-2176

Fax: 703-218-2160

Brad.Jones@opflaw.com

UNITED STATES BANKRUPTCY COURT

FOR THE EASTERN DISTRICT OF VIRGINIA

Alexandria Division

In re: )

)

GBEKU GREGORY WRIGHT, ) Case No. 19-12994-BFK

) Chapter 7

Debtor. )

_____________________________________________________________________

BRANCH BANKING & TRUST COMPANY, )

)

Movant, )

)

v. )

)

GBEKU GREGORY WRIGHT, )

)

and )

)

DONALD F. KING, TRUSTEE )

)

Respondents. )

ANSWER

DONALD F. KING, TRUSTEE (the “Trustee”), by counsel, files his Answer to the 

Motion for Relief From the Automatic Stay (the “Motion”) filed by Branch Banking & 

Trust Company (“Movant”) in the above referenced case for the property located at 

7411 Farmcrest Drive, New Carrollton, Maryland (the “Property”), and states as 

follows:

1. The Trustee admits the allegations contained in Paragraphs 1 and 2. 

Case 19-12994-BFK Doc 13 Filed 10/22/19 Entered 10/22/19 18:59:21 Desc Main

 Document Page 1 of 4
- 2 -

2. The Trustee, lacking sufficient knowledge of the allegations contained in 

Paragraphs 3, 4, 5, 6, 7, 8, 9, and 10 of the Motion, neither admits nor denies such 

allegations and requires proof thereof. 

3. The Trustee denies the allegation contained in Paragraph 11 and 12 of the 

Motion.

AFFIRMATIVE DEFENSE

Assuming, without admitting, that Movant’s allegations in the Motion are 

correct, there is a significant equity cushion protecting Movant’s alleged interest in the 

Property. Movant alleges that the total amount due under its Note with the Debtor is 

$81,395.57 as of September 12, 2019. Dkt. No. 10 at 2. Movant also alleges there is a 

first lien on the Property with an approximate value of $142,000.00. Id. The Property 

has a Zillow valuation of $281,661. As a result, there appears to be significant equity, 

and the Trustee is currently investigating the Property to determine if this asset can 

be administered for the benefit of creditors. 

If the Property is sold, the Movant’s debt will be paid in full from any sale of the 

Property by the Trustee or on terms that are agreeable to the Movant. As a result, the 

Trustee believes that Movant’s alleged interests are adequately protected by the equity 

cushion in the Property. 

Case 19-12994-BFK Doc 13 Filed 10/22/19 Entered 10/22/19 18:59:21 Desc Main

 Document Page 2 of 4
- 3 -

WHEREFORE, Donald F. King, Trustee, by counsel, requests that this Court 

enter an order denying Movant’s Motion for Relief from the Automatic Stay. 

DONALD F. KING, TRUSTEE

By Counsel

By: /s/ Bradley Jones

Bradley Jones (VSB No. 85095)

Counsel for Trustee

ODIN FELDMAN & PITTLEMAN PC

1775 Wiehle Avenue, Suite 400

Reston, Virginia 20190

Phone: 703-218-2176

Fax: 703-218-2160

Brad.Jones@ofplaw.com 

Case 19-12994-BFK Doc 13 Filed 10/22/19 Entered 10/22/19 18:59:21 Desc Main

 Document Page 3 of 4
- 4 -

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a true and accurate copy of the Answer was sent via 

Notice of Electronic Filing upon counsel for Movant, counsel for Debtor, and all 

registered users in this case pursuant to this Court’s CM/ECF policy.

/s/ Bradley Jones

Bradley Jones

#4441736v1 31070/00001

Case 19-12994-BFK Doc 13 Filed 10/22/19 Entered 10/22/19 18:59:21 Desc Main

 Document Page 4 of 4