UNITED STATES BANKRUPTCY COURT

SOUTHERN DISTRICT OF FLORIDA

MIAMI DIVISION

PRELIMINARY RESPONSE TO 

DEBTOR’S RESPONSE TO RULE 3002.1 

NOTICE [ECF NO. 67] IN RELATION TO CLAIM NO 6 [D.E. 68]

COMES NOW, Creditor, Wilmington Trust, National Association, as Successor Trustee 

to Citibank, N.A., as Trustee for Bear Stearns ALT-A Trust, Mortgage Pass-Through Certificates, 

Series 2007-3 (“Secured Creditor”), and files this written response to the Debtor’s Response to 

Rule 3002.1 Notice [ECF No. 67] in Relation to Claim No 6 [D.E. 68], and as grounds therefor 

states:

1. On June 3, 2020, Claim 6-1 was filed in the instant case reflecting a secured claim 

against the Debtor’s property, 170 East 5th Street, Hialeah, Florida 33010, in the 

amount of $ 253,756.43. 

2. On February 14, 2022, the Debtor filed this instant Response to 3002.1 Notice [ECF 

No. 67] in Relation to Claim No 6 [D.E. 68]. Debtor’s Response contends that the 

Debtor provided proof of homeowner’s insurance and Secured Creditor is accounting 

for lender placed hazard insurance in the escrow portion of the monthly payment. The 

Debtor is objecting to the lender placed insurance.

3. Secured Creditor needs additional time to review its records to respond to the 

allegations contained in the response.

Case No.: 20-12418-LMI

Chapter 13

Judge: Laurel M Isicoff

IN RE: 

CRISTINA BONETTI

aka Cristina Maria Bonetti

aka Cristina M Bonetti

Debtor(s). /

Case 20-12418-LMI Doc 72 Filed 02/23/22 Page 1 of 4
4. Secured Creditor reserves the right to supplement its response.

WHEREFORE, Wilmington Trust, National Association, as Successor Trustee to Citibank, 

N.A., as Trustee for Bear Stearns ALT-A Trust, Mortgage Pass-Through Certificates, Series 2007-

3 requests that this Court deny the Debtor’s Response to Rule 3002.1 Notice [ECF No. 67] in 

Relation to Claim No 6 [D.E. 68] and grant such other and further relief as the Court deems just 

and proper.

DATED this 23rd day of February 2022

Respectfully submitted, 

/S/ Seth Greenhill_______________

SETH GREENHILL, ESQ.

Florida Bar # 97938

PADGETT LAW GROUP

6267 Old Water Oak Road, Suite 203

Tallahassee, FL 32312

(850) 422-2520 (telephone)

(850) 422-2567 (facsimile)

Seth.Greenhill@padgettlawgroup.com

Attorney for Creditor

Case 20-12418-LMI Doc 72 Filed 02/23/22 Page 2 of 4
CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished to 

the parties on the attached Service List by electronic notice and/or by First Class U.S. Mail on this

23rd day of February 2022:

/S/ Seth Greenhill_______________

SETH GREENHILL, ESQ.

Florida Bar # 97938

PADGETT LAW GROUP

6267 Old Water Oak Road, Suite 203

Tallahassee, FL 32312

(850) 422-2520 (telephone)

(850) 422-2567 (facsimile)

Seth.Greenhill@padgettlawgroup.com

Attorney for Creditor

Case 20-12418-LMI Doc 72 Filed 02/23/22 Page 3 of 4
SERVICE LIST (CASE NO. 20-12418-LMI)

Debtor

Cristina Bonetti

170 E 5th St, Unit 2

Hialeah, FL 33010

aka Cristina Maria Bonetti

aka Cristina M Bonetti

Attorney for Debtor

Samir Masri

901 Ponce de Leon Blvd #101

Coral Gables, FL 33134

Trustee

Nancy K. Neidich

POB 279806

Miramar, FL 33027

U.S. Trustee

Office of the US Trustee

51 S.W. 1st Ave.

Suite 1204

Miami, FL 33130

Case 20-12418-LMI Doc 72 Filed 02/23/22 Page 4 of 4