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UNITED STATES BANKRUPTCY COURT 

SOUTHERN DISTRICT OF FLORIDA 

www.flsb.uscourts.gov

In re: Liannys Fidalgo Case No. 19-23683-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 

17 Bank of America $7235.64

Basis for Objection and Recommended Disposition

On or about December 10, 2019, Creditor filed a secured proof of claim in the amount of $7,235.64

and an arrearage in the amount of $286.74 for a 2014 Honda Accord Sport Vin: 

1HGCR2F53EA048774, account ending in 8463. The Debtor’s confirmed plan treats this claim 

outside the plan and paid directly to the Creditor. Debtor requests the claim be allowed as filed with 

no distribution from the Chapter 13 Trustee.

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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 September 23, 2020

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

to: 

Bank of America

Attn: Danette Murrell, AVP

Nc4-105-03-14 Pob 26012

Greensboro, NC 27420

Bank of America, N.A.

Attn: Danette Murrell, AVP

PO BOX 31785

Tampa, FL 33631-3785

Bank of America, N.A.

Attn: Danette Murrell, AVP

16001 N. Dallas Pkwy

Addison, TX 75001

Certified Mail: 

Bank of America, N.A.

c/o Brian Moynihan, CEO

100 N. Tryon Street

Charlotte, NC 28255

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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