LF-31 (rev. 10/3/17) Page 1 of 3

 UNITED STATES BANKRUPTCY COURT, SOUTHERN DISTRICT OF FLORIDA

www.flsb.uscourts.gov

CHAPTER 13 PLAN (Individual Adjustment of Debts)

■

Original Plan 

3rd Amended Plan (Indicate 1st, 2nd, etc. Amended, if applicable)

Modified Plan (Indicate 1st, 2nd, etc. Modified, if applicable)

DEBTOR: Katia De La Cruz JOINT DEBTOR: CASE NO.: 19-19265-RAM

SS#: xxx-xx- 9116 SS#: xxx-xxI. NOTICES 

To Debtors: Plans that do not comply with local rules and judicial rulings may not be confirmable. All plans, amended plans 

and modified plans shall be served upon all creditors and a certificate of service filed with the Clerk pursuant to 

Local Rules 2002-1 (C)(5), 3015-1(B)(2), and 3015-2. Debtor(s) must commence plan payments within 30 days of 

filing the chapter 13 petition or within 30 days of entry of the order converting the case to chapter 13. 

 To Creditors: Your rights may be affected by this plan. You must file a timely proof of claim in order to be paid. Your claim may 

be reduced, modified or eliminated. 

 To All Parties: The plan contains no nonstandard provisions other than those set out in paragraph VIII. Debtor(s) must check one 

box on each line listed below in this section to state whether the plan includes any of the following:

The valuation of a secured claim, set out in Section III, which may result in a 

partial payment or no payment at all to the secured creditor Included ■ Not included

Avoidance of a judicial lien or nonpossessory, nonpurchase-money security interest, set 

out in Section III Included ■ Not included

Nonstandard provisions, set out in Section VIII Included ■ Not included

II. PLAN PAYMENTS, LENGTH OF PLAN AND DEBTOR(S)' ATTORNEY'S FEE

A. MONTHLY PLAN PAYMENT: This Plan pays for the benefit of the creditors the amounts listed below, including trustee's 

fees of 10%, beginning 30 days from the filing/conversion date. In the event the trustee does not retain the full 10%, any unused 

amount will be paid to unsecured nonpriority creditors pro-rata under the plan:

1. $335.88 for months 1 to 60 ;

B. DEBTOR(S)' ATTORNEY'S FEE: NONE PRO BONO

Total Fees: $3650.00 Total Paid: $1590.00 Balance Due: $2060.00 

Payable $103.00 /month (Months 1 to 20 )

Allowed fees under LR 2016-l(B)(2) are itemized below:

$3500 Attorneys Fees + $150 Cost = $3650

Applications for compensation must be filed for all fees over and above the Court's Guidelines for Compensation.

III. TREATMENT OF SECURED CLAIMS

A. SECURED CLAIMS: ■ NONE

[Retain Liens pursuant to 11 U.S.C. §1325 (a)(5)] Mortgage(s)/Lien on Real or Personal Property:

B. VALUATION OF COLLATERAL: ■ NONE

C. LIEN AVOIDANCE ■ NONE

D. SURRENDER OF COLLATERAL: Secured claims filed by any creditor granted stay relief in this section shall not receive a 

distribution fom the Chapter 13 Trustee.

■ NONE

E. DIRECT PAYMENTS: Secured claims filed by any creditor granted stay relief in this section shall not receive a distribution 

fom the Chapter 13 Trustee.

NONE

Case 19-19265-RAM Doc 40 Filed 09/20/19 Page 1 of 3
LF-31 (rev. 10/3/17) Page 2 of 3

Debtor(s): Katia De La Cruz Case number: 19-19265-RAM

The debtor(s) elect to make payments directly to each secured creditor listed below. The debtor(s) request that upon 

confirmation of this plan the automatic stay be terminated in rem as to the debtor(s) and in rem and in personam as to any 

codebtor(s) as to these creditors. Nothing herein is intended to terminate or abrogate the debtor(s)' state law contract rights. 

■

Name of Creditor Last 4 Digits of Account No. Description of Collateral (Address, Vehicle, etc.)

1.

Pennymac Loan Services 6258 6622 NW 181 Lane, Hialeah, FL 33015

2.

The Moors Master 

Maintenance Association

8539 6622 NW 181 Lane Hialeah, FL 33015

IV. TREATMENT OF FEES AND PRIORITY CLAIMS [as defined in 11 U.S.C. §507 and 11 U.S.C. § 1322(a)(4)]

A. ADMINISTRATIVE FEES OTHER THAN DEBTORS(S)' ATTORNEY'S FEE: ■ NONE

B. INTERNAL REVENUE SERVICE: NONE

Total Due: $8,078.59 Total Payment $8,078.59 

Payable: $134.64 /month (Months 1 to 60 )

C. DOMESTIC SUPPORT OBLIGATION(S): ■ NONE

D. OTHER: ■ NONE

V. TREATMENT OF UNSECURED NONPRIORITY CREDITORS

A. Pay $64.61 /month (Months 1 to 20 )

Pay $167.61 /month (Months 21 to 60 )

Pro rata dividend will be calculated by the Trustee upon review of filed claims after bar date.

B. If checked, the Debtor(s) will amend/modify to pay 100% to all allowed unsecured nonpriority claims.

C. SEPARATELY CLASSIFIED: ■ NONE

*Debtor(s) certify the separate classification(s) of the claim(s) listed above will not prejudice other unsecured nonpriority 

creditors pursuant to 11 U.S.C. § 1322.

VI. EXECUTORY CONTRACTS AND UNEXPIRED LEASES: Secured claims filed by any creditor/lessor granted stay relief in this 

section shall not receive a distribution from the Chapter 13 Trustee.

NONE

Unless provided for under a separate section, the debtor(s) request that upon confirmation of this plan, the automatic stay be 

terminated in rem as to the debtor(s) and in rem and in personam as to any codebtor(s) as to these creditors/lessors. Nothing 

herein is intended to terminate or abrogate the debtor(s)' state law contract rights. 

■

Name of Creditor Collateral Acct. No. (Last 4 Digits) Assume/Reject

1.

Almacen Y Muebleria La Florida 

USA

None None

Assume ■ Reject

2.

Hyundai Motor Finance 2017 Hyundai Santa Fe Sport 0488

■ Assume Reject

VII. INCOME TAX RETURNS AND REFUNDS: ■ NONE

VIII. NON-STANDARD PLAN PROVISIONS ■ NONE

Case 19-19265-RAM Doc 40 Filed 09/20/19 Page 2 of 3
LF-31 (rev. 10/3/17) Page 3 of 3

Debtor(s): Katia De La Cruz Case number: 19-19265-RAM

Debtor

Katia De La Cruz Date

Attorney with permission to sign on 

Debtor(s)' behalf

/s/Robert Sanchez, Esq.

Date

September 20, 2019

Joint Debtor

Date

PROPERTY OF THE ESTATE WILL VEST IN THE DEBTOR(S) UPON PLAN CONFIRMATION. 

 

I declare that the foregoing chapter 13 plan is true and correct under penalty of perjury. 

By filing this document, the Attorney for Debtor(s) or Debtor(s), if not represented by counsel, certifies that the wording and 

order of the provisions in this Chapter 13 plan are identical to those contained in Local Form Chapter 13 Plan and the plan 

contains no nonstandard provisions other than those set out in paragraph VIII.

Case 19-19265-RAM Doc 40 Filed 09/20/19 Page 3 of 3