PH # 102068 1 

UNITED STATES BANKRUPTCY COURT 

SOUTHERN DISTRICT OF FLORIDA 

MIAMI DIVISION 

In Re: 

SOLANGEL M. BELLO 

A/K/A SOLANGEL D. BELLO 

A/K/A SOLANGEL MERECDES BELLO 

A/K/A SOLANGEL BELLO, 

 Bk No.: 19-20216-AJC 

Chapter 13 

Debtor / 

EX-PARTE MOTION TO APPROVE LOAN MODIFICATION AGREEMENT 

Comes now, U.S. Bank Trust, N.A., as Trustee for Lsrmf Mh Master Participation Trust 

II, by and through Counsel undersigned and files this Motion to Approve Loan Modification 

Agreement and in support thereof would state as follows: 

1. The Debtor has been offered an attached loan modification per the terms of the 

offer attached as an exhibit hereto. 

2. The Lender has approve the Debtor for trial loan modification. The trial 

modification will consist of three payments of $1,713.93 being made over three months. The 

payments need to be made on April 1, 2020, May 1, 2020 and June 1, 2020. Once the last trial 

payment has been made successfully, then the Lender will offer a permanent loan modification. 

3. Payment(s) made to the Chapter 13 Trustee constitute timely payments made to 

Creditor, during the remainder of the Plan and the Debtor will continue making the modified 

mortgage payments after the Plan has completed. 

4. If the Trustee is disbursing payments to Creditor or is holding remaining funds, 

the Trustee shall disburse payments as soon as practicable. 

5. The payment address is: 

CALIBER HOME LOANS, INC. 

P.O. Box 24330 

Oklahoma City, OK 73124-0330 

Case 19-20216-AJC Doc 77 Filed 02/17/20 Page 1 of 10
PH # 102068 2 

 WHEREFORE, Creditor requests Ex Parte Motion to Approve Mortgage Modification 

Agreement be granted and for such other and further relief as this Court deems proper. 

I HEREBY CERTIFY, that I am admitted to 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). 

February 14, 2020 

/s/ Brenda Carpenter, Esquire 

Brenda Carpenter, Esq., Florida Bar No. 108351 

Phelan Hallinan Diamond & Jones, PLLC 

2001 NW 64th Street 

Suite 100 

Ft. Lauderdale, FL 33309 

Tel: 954-462-7000 Ext. 53343 

Fax: 954-462-7001 

Email: brenda.carpenter@phelanhallinan.com 

FLSD.bankruptcy@phelanhallinan.com

Case 19-20216-AJC Doc 77 Filed 02/17/20 Page 2 of 10
Case 19-20216-AJC Doc 77 Filed 02/17/20 Page 3 of 10
Case 19-20216-AJC Doc 77 Filed 02/17/20 Page 4 of 10
Case 19-20216-AJC Doc 77 Filed 02/17/20 Page 5 of 10
Case 19-20216-AJC Doc 77 Filed 02/17/20 Page 6 of 10
Case 19-20216-AJC Doc 77 Filed 02/17/20 Page 7 of 10
Case 19-20216-AJC Doc 77 Filed 02/17/20 Page 8 of 10
Case 19-20216-AJC Doc 77 Filed 02/17/20 Page 9 of 10
PH # 102068 

CERTIFICATE OF SERVICE

 I HEREBY CERTIFY that a true and correct copy of the foregoing, and any 

applicable exhibits attached thereto, has been served electronically, or routed for service by U.S. 

Mail, to the following: 

SOLANGEL M. BELLO 

16424 NW 77TH PATH 

MIAMI LAKES, FL 33016 

TIMOTHY S. KINGCADE, ESQ, Esquire 

1370 CORAL WAY 

MIAMI, FL 33145 

NANCY K. NEIDICH, (TRUSTEE) 

WWW.CH13MIAMI.COM, POB 279806 

MIRAMAR, FL 33027 

UNITED STATES TRUSTEE (SERVED ELECTRONICALLY) 

OFFICE OF THE UNITED STATES TRUSTEE 

51 SW FIRST AVENUE, ROOM 1204 

MIAMI, FL 33130 

Date: /s/ Brenda Carpenter, Esquire 

Brenda Carpenter, Esq., Florida Bar No. 108351 

Phelan Hallinan Diamond & Jones, PLLC 

2001 NW 64th Street 

Suite 100 

Ft. Lauderdale, FL 33309 

Tel: 954-462-7000 Ext. 53343 

Fax: 954-462-7001 

Email: brenda.carpenter@phelanhallinan.com 

FLSD.bankruptcy@phelanhallinan.com

Case 19-20216-AJC Doc 77 Filed 02/17/20 Page 10 of 10