IN THE UNITED STATES BANKRUPTCY COURT

FOR THE NORTHERN DISTRICT OF ILLINOIS, EASTERN DIVISION

In Re: ) Case No.: 16-27657

Kathy S Grogan ) Chapter 13

Debtor(s). ) Judge: Pamela S. Hollis

 

NOTICE OF MOTION

TO: Kathy S Grogan, 2139 Wilson Creek Circle Aurora, IL 60503 via US mail

Glenn Stearns, Chapter 13 Trustee, 801 Warrenville Rd. Suite 650, Lisle, IL 60532 via 

ECF clerk’s electronic delivery system

U.S. Trustee, 219 S. Dearborn Suite 873, Chicago IL 60604 via ECF clerk’s electronic 

delivery system 

Notice address for JPMorgan Chase Bank, NA: JPMorgan Chase Bank, NA. Chase 

Records Center Attn: Correspondence Mail, Mail Code LA4-5555 700 Kansas Lane

Monroe, LA 71203 via US mail

Attorneys for JPMorgan Chase Bank, NA: Peter C Bastianen, Codilis & Associates, PC,

15W030 N Frontage Rd., Suite 100 Burr Ridge, IL 60527 via US mail

See attached service list

PLEASE TAKE NOTICE that on September 6, 2019 at 10:45 a.m., I shall appear 

before the Honorable Judge Pamela S. Hollis at Joliet City Hall, 150 West Jefferson Street, 2nd 

Floor Joliet, Illinois 60432 or any judge presiding and then and there present the Motion, a copy 

of which is attached hereto.

By: /s/ David H. Cutler

David H. Cutler

CERTIFICATE OF SERVICE

I, David H. Cutler, hereby certify that I caused to be served, electronically or through U.S. 

Mail, a copy of the foregoing Notice and Motion upon the parties named above on August 16, 

2019 before the hour of 7:00 p.m.

By: /s/ David H. Cutler

David H. Cutler, esq.

Counsel for Debtor(s)

Cutler & Associates, Ltd.

4131 Main St.

Skokie, IL 60076

Phone: (847) 673-8600

Case 16-27657 Doc 46 Filed 08/16/19 Entered 08/16/19 18:11:34 Desc Main

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IN THE UNITED STATES BANKRUPTCY COURT

FOR THE NORTHERN DISTRICT OF ILLINOIS, EASTERN DIVISION

In Re: ) Case No.: 16-27657

Kathy S Grogan ) Chapter 13

Debtor(s). ) Judge: Pamela S. Hollis

 

MOTION TO MODIFY PLAN POST CONFIRMATION

NOW COMES the Debtor, Kathy S Grogan, (hereafter referred to as “the Debtor”), by 

and through her attorneys, The Law Offices of Cutler & Associates, Ltd., to present this Motion 

and state as follows:

1. This Court has jurisdiction over this proceeding pursuant to 28 USC 1334 and this is a 

"core proceeding" under 28 USC 157(b)(2). 

2. The Debtor filed for relief under Chapter 13 of the United States Bankruptcy Code on

August 29, 2016 and her Plan was confirmed.

3. The Debtor’s confirmation Order provides for a plan payment of $1,135 for 60 months 

with unsecured creditors receiving 41% of their unsecured claims.

4. Paragraph E.5 of the confirmed plan provides for payments to JPMorgan Chase Bank, 

NA. for pre-petition arrears in the amount of $12,946.28.

5. The Debtor had entered into a loan modification with JPMorgan Chase Bank, NA. on or 

around September, 2017, and the loan modification included pre-petition arrears as of the 

loan modification. 

6. Since the pre-petition arrears as of the loan modification are being covered in the loan 

modification and JPMorgan Chase Bank, NA. retuned funds sent to them from the 

Trustee’s office that a loan modification has been completed on the account, the Debtor is 

Case 16-27657 Doc 46 Filed 08/16/19 Entered 08/16/19 18:11:34 Desc Main

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requesting that the Trustee should not make any further disbursements to JPMorgan 

Chase Bank, NA.

WHEREFORE, the Debtor respectfully requests that this Court modify the Debtor’s Plan 

Post Confirmation by directing the Trustee to not make any further disbursements to JPMorgan 

Chase Bank, NA.; and for such further relief that this Court may deem just and proper.

Dated: August 16, 2019 Respectfully Submitted,

By: /s/ David H. Cutler 

David H. Cutler, esq.,

Counsel for Debtor(s):

Cutler & Associates, Ltd.

4131 Main St.

Skokie, IL 60076

Phone: (847) 673-8600

Case 16-27657 Doc 46 Filed 08/16/19 Entered 08/16/19 18:11:34 Desc Main

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