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UNITED STATES BANKRUPTCY COURT 

SOUTHERN DISTRICT OF FLORIDA 

www.flsb.uscourts.gov

In re: Juan Cabrera Hernandez Case No. 19-21400-RAM

 Chapter 13

Debtor(s) /

OBJECTION TO CLAIM 

IMPORTANT NOTICE TO CREDITOR:

THIS IS AN OBJECTION TO YOUR CLAIM

This objection seeks either to disallow or reduce the amount or change the 

priority status of the claim filed by you or on your behalf. Please read this objection 

carefully to identify which claim is objected to and what disposition of your claim is 

recommended.

If you disagree with the objection or the recommended treatment, you must 

file a written response WITHIN 30 DAYS from the date of service of this objection, 

explaining why your claim should be allowed as presently filed, and you must serve 

a copy to the undersigned [attorney][trustee] OR YOUR CLAIM MAY BE DISPOSED 

OF IN ACCORDANCE WITH THE RECOMMENDATION IN THIS OBJECTION.

If your entire claim is objected to and this is a chapter 11 case, you will not

have the right to vote to accept or reject any proposed plan of reorganization until 

the objection is resolved, unless you request an order pursuant to Bankruptcy Rule

3018(a) temporarily allowing your claim for voting purposes.

The written response must contain the case name, case number, and must be 

filed with the Clerk of the United States Bankruptcy Court.

301 North Miami Avenue, Room 150, Miami, FL 33128

Pursuant to Bankruptcy Rule 3007 and Local Rule 3007-1, Debtor objects to the following claim(s) 

filed in this case:

Claim Amount of

No. Name of Claimant Claim 

3 Quantum3 Group LLC as agent for Aqua Finance Inc $6,801.09

Basis for Objection and Recommended Disposition

On or about September 17, 2019, Creditor filed a fully secured proof of claim in the amount of 

$6,801.09 for a household good credit account ending in 3722. The Debtor’s interest in the collateral 

securing this debt was surrendered by the Debtor in the confirmed plan since the collateral was 

broken. The Debtor requests this debt be allowed as filed without a distribution from the Chapter 13 

Trustee as the collateral has been surrendered by the Debtor in full satisfaction of the claim and 

without any in personam liability to the Debtor. 

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WHEREFORE the above-mentioned Debtor, respectfully requests that the Court grant the relief 

sought herein.

*Notwithstanding the requirements of Bankruptcy Rule 3007, up to five objections to claim may be 

included in one pleading. (See Local Rule 3007-1(C).)

 CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a true copy of the foregoing was sent on April 29, 2020 electronically to 

Nancy K. Neidich, Trustee and mailed via U.S. First-Class Mail, unless otherwise noted, to:

Quantum3 Group LLC 

c/o Kayla Klabunde, Auth. Agent

PO Box 788 

Kirkland WA 98083-0788

CERTIFICATE OF ADMISSION

I HEREBY CERTIFY that I am a member of the Bar of the United States District Court for the 

Southern District of Florida and I am in compliance with the additional qualifications to practice in this Court 

set forth in Local Rule 2090-1(A). 

Respectfully Submitted: 

Robert Sanchez, P.A. 

Attorney for Debtor 

355 West 49th Street 

Hialeah, FL 33012

Tel. 305-687-8008

Fax. 305-512-9701

By: /s/ Robert Sanchez________________

 [X]Robert Sanchez, Esq., FBN#0442161

 

The party filing this objection to claim must file a certificate of service in accordance with Local Rule 2002-

1(F).

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