LF-70 (rev. 12/01/09)

UNITED STATES BANKRUPTCY COURT

SOUTHERN DISTRICT OF FLORIDA

www.flsb.uscourts.gov

In re: Case No.: 19-20404-RAM

Chapter 13

Carolyn Ruiz

 Debtor(s) /

OBJECTION TO CLAIM ON SHORTENED NOTICE

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. Upon the filing of this objection an expedited hearing on this 

objection will be scheduled on the date already scheduled for the confirmation 

hearing in accordance with Local Rule 3007-1(B)(2).

Pursuant to Bankruptcy Rule 3007 and Local Rule 3007-1(B)(2), the 

[trustee][debtor] objects to the following claim filed in this case:

Claim Amount of

No. Name of Claimant Claim 

3 LVNV Funding, LLC / $590.09

Resurgent Capital Services

Basis for Objection and Recommended Disposition

On or about August 14, 2019, Creditor filed a general unsecured proof of claim in the amount of $590.09

for a Retail account ending in xxxxxxxxxxxx0823. This debt is not listed on the Debtor’s schedule “F”, which 

was obtained from the Debtor’s credit report. Further, this creditor has failed to attach any substantiating 

backup documentation to prove its claim. Furthermore, this claim is barred by the statute of limitations as 

the backup documentation shows this debt was last active on or about March 2, 2002. Debtors request this 

claim be stricken and disallowed.

Debtor’s counsel has been forced to file this Objection to Claim in response to creditor’s filing of an improper 

Proof of Claim which would never be allowed. Therefore, the Debtor respectfully requests this Court award 

reasonable attorney’s fees and costs to Debtor’s counsel for bringing this objection. 

Claim Amount of

No. Name of Claimant Claim 

10 LVNV Funding, LLC / $807.49

Resurgent Capital Services

Basis for Objection and Recommended Disposition

On or about October 10, 2019, Creditor filed a general unsecured proof of claim in the amount of $807.49

for a Retail account ending in xxxxxxxxxxxx2823. This debt is not listed on the Debtor’s schedule “F”, which 

was obtained from the Debtor’s credit report. Further, this creditor has failed to attach any substantiating 

backup documentation to prove its claim. Furthermore, this claim is barred by the statute of limitations as 

the backup documentation shows this debt was last active on or about April 1, 2002. Debtors request this 

claim be stricken and disallowed.

Debtor’s counsel has been forced to file this Objection to Claim in response to creditor’s filing of an improper 

Proof of Claim which would never be allowed. Therefore, the Debtor respectfully requests this Court award 

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LF-70 (rev. 12/01/09)

reasonable attorney’s fees and costs to Debtor’s counsel for bringing this objection. 

The undersigned acknowledges that this objection and the notice of hearing for this 

objection will be served on the claimant and the debtor at least 14 days prior to the 

confirmation hearing date and that a certificate of service conforming to Local Rule 2002-

1(F) must be filed with the court when the objection and notice of hearing are served.

DATED: May 12, 2020 Respectfully Submitted: 

Robert Sanchez, P.A.

355 West 49th Street

Hialeah, FL 33012

Fl. Bar No. 0442161

Telephone: (305) 687-8008

E-Mail: court@bankruptcyclinic.com

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