UNITED STATES BANKRUPTCY COURT

SOUTHERN DISTRICT OF FLORIDA

FT. LAUDERDALE DIVISION

IN RE:

MAURICE YOUNG, 

Debtor,

_________________________________/

CASE NO.: 19-20485-BKC-JKO

CHAPTER 13

SUPPLEMENTAL RESPONSE TO DEBTOR’S OBJECTION TO CLAIM NO. 3 FILED 

BY WILMINGTON SAVINGS FUND SOCIETY, FSB, D/B/A CHRISTIANA TRUST, 

NOT INDIVIDUALLY BUT AS TRUSTEE FOR PRETIUM MORTGAGE 

ACQUISITION TRUST

COMES NOW, WILMINGTON SAVINGS FUND SOCIETY, FSB, D/B/A 

CHRISTIANA TRUST, NOT INDIVIDUALLY BUT AS TRUSTEE FOR PRETIUM 

MORTGAGE ACQUISITION TRUST (“Secured Creditor”), by and through its undersigned 

attorney, hereby files its Supplemental Response to Debtor’s Objection To Claim No. 3 Filed By 

Wilmington Savings Fund Society, Fsb, D/B/A Christiana Trust, Not Individually But As Trustee 

For Pretium Mortgage Acquisition Trust (“Objection”), (DE# 69), and in support thereof states as 

follows:

1. On December 26, 2019, Secured Creditor filed its Response to Debtor’s Objection to 

Claim No. 3 Filed By Wilmington Savings Fund Society, Fsb, D/B/A Christiana Trust, 

Not Individually But As Trustee For Pretium Mortgage Acquisition Trust (DE # 76). 

2. Secured Creditor is filing this Supplemental Response to provide the Debtor with the 

below breakdown of the Prepetition Fees Due and to attach two additional exhibits.

12/18/2017 $63.06 Late Charges

1/16/2018 $63.06 Late Charges

2/16/2018 $63.06 Late Charges

3/16/2018 $63.06 Late Charges

4/16/2018 $63.06 Late Charges

5/16/2018 $63.06 Late Charges

6/18/2018 $63.06 Late Charges

Case 19-20485-PGH Doc 77 Filed 01/02/20 Page 1 of 3
7/16/2018 $63.06 Late Charges

8/1/2018 $15.00 Property Inspection

8/16/2018 $63.06 Late Charges

10/3/2018 $15.00 Property Inspection

10/25/2018 $1035.00 FC Costs

10/30/2018 $690.00 FC Costs

10/30/2018 $410.00 FC Costs

10/30/2018 $05.00 FC Costs

10/30/2018 $1991.00 FC Costs

10/30/2018 $690.00 FC Costs

10/30/2018 $155.00 FC Fees

11/7/2018 $15.00 Property Inspection

1/3/2019 $15.00 Property Inspection

2/4/2019 $690.00 FC Fees

2/8/2019 $250.00 FC Costs

2/13/2019 $328.46 BK Fees

5/11/2019 $15.00 Property Inspection

6/13/2019 $250.00 FC Fees

6/14/2019 $05.00 FC Costs

6/14/2019 $50.00 FC Costs

7/10/2019 $250.00 FC Fees

7/13/2019 $15.00 Property Inspection

7/16/2019 $70.00 FC Costs

7/16/2019 $05.00 FC Costs

7/16/2019 $250.00 FC Fees

7/24/2019 $250.00 FC Fees

7/29/2019 $245.00 FC Costs

WHEREFORE, Secured Creditor respectfully requests that this Honorable Court 

overrules Debtor’s objection and allows Secured Creditor's Proof of Claim as filed so as to 

preserve Creditor's Claim, and for such other and further relief as the Court may deem just 

and proper.

ROBERTSON, ANSCHUTZ & SCHNEID, P.L.

Attorney for Secured Creditor

6409 Congress Ave., Suite 100

Boca Raton, FL 33487

Telephone: 561-241-6901

Facsimile: 561-241-1969

By: /s/ Ashley French

Ashley French, Esquire

Email: afrench@rasflaw.com

Florida Bar No. 107296

Case 19-20485-PGH Doc 77 Filed 01/02/20 Page 2 of 3
CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on January 2, 2020, I caused to be electronically filed the 

foregoing with the Clerk of Court by using the CM/ECF system, and a true and correct copy has 

been served via CM/ECF or United States Mail to the following parties:

DEBTOR

Maurice Young

16573 SW 19th Street

Miramar, FL 33027

DEBTOR COUNSEL

Michael A. Frank, Esq. 

10 NW LeJeune Rd. #620

Miami, FL 33126

TRUSTEE

Robin R. Weiner 

PO Box 559007

Fort Lauderdale, FL 33355

U.S. TRUSTEE

Office of the U.S.Trustee

2025 Robert C. Byrd, US Courthouse

300 Virginia Street, East

Charleston, WV 25301

ROBERTSON, ANSCHUTZ & SCHNEID, P.L.

Attorney for Secured Creditor

6409 Congress Ave., Suite 100

Boca Raton, FL 33487

Telephone: 561-241-6901

Facsimile: 561-241-1969

By: /s/ Ashley French

Ashley French, Esquire

Email: afrench@rasflaw.com

Florida Bar No. 107296

Case 19-20485-PGH Doc 77 Filed 01/02/20 Page 3 of 3