UNITED STATES BANKRUPTCY COURT 

SOUTHERN DISTRICT OF FLORIDA 

FORT LAUDERDALE DIVISION 

IN RE: CASE NO.: 20-12895-PDR

CHARLES RAYFIELD RHODES CHAPTER 13

Debtor. 

_____________________________________/

CITY OF HOLLYWOOD’S

OBJECTION TO CONFIRMATION 

The City of Hollywood, by and through its undersigned attorney, hereby objects to 

confirmation of the Debtor’s Fifth Amended Chapter 13 Plan (the “Plan”) [D.E. 131] and in 

support thereof states as follows: 

FACTS

1. On March 2, 2020, Charles Rayfield Rhodes (the “Debtor”) filed his voluntary petition for 

relief under Chapter 13 of Title 11 of the United States Code (the “Bankruptcy Code”).

2. On or about May 17, 2021, while conducting a public bankruptcy search the City of 

Hollywood learned of the Debtor’s filing. 

3. Federal Bankruptcy Rule 1007(a)(1) states that a debtor shall file with the petition a list 

containing the name and address of each entity to be included on schedules and the debtor shall

file a supplemental statement promptly upon any change in circumstances. 

4. The Debtor is aware of all debts owed to the City of Hollywood and is currently in active 

litigation against the City of Hollywood. 

4. The City of Hollywood is creditor secured by lien(s) on property in which the estate has an 

interest, therefore City of Hollywood should have been listed and provided noticed. 

Case 20-12895-PDR Doc 133 Filed 05/27/21 Page 1 of 3
5. The City of Hollywood contends that the Debtor’s Plan fails to provide for payment of its 

secured claims. 

6. Therefore, the Debtor’s Plan cannot be confirmed. 

WHEREFORE, the City of Hollywood respectfully request that the Court enter an Order: 

(i) denying confirmation of the Debtor’s Plan; (ii) require the Debtor to file a plan that includes 

any and all of City of Hollywood claims; and (iii) providing for such further relief as this Court 

deems just and proper. 

Respectfully submitted,

DOUGLAS R. GONZALES,

CITY ATTORNEY

City of Hollywood

2600 Hollywood Boulevard

Room 407

Hollywood, FL 33020

Telephone: (954) 921-3435

Telecopier: (954) 921-3081

By: /s/Kendra Breeden Esq. 

 Kendra Breeden Esq.

 Collections Attorney 

 Fla. Bar No. 111383

 kbreeden@hollywoodfl.org

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on May 27, 2021 I electronically filed the foregoing

document with the Clerk of the Court using CM/ECF. I also certify that the foregoing document

is being served this day by transmission of Notices of Electronic Filing generated by CM/ECF to

those parties registered to receive electronic notices of filing in this case or via U.S. mail as listed

in the below Service List.

Case 20-12895-PDR Doc 133 Filed 05/27/21 Page 2 of 3
VIA CM/ECF:

20-12895-PDR Notice will be electronically mailed to:

Robert J. Bigge Jr., Esq on behalf of Debtor Charles Rayfield Rhodes

brpa@biggerodriguez.com, biggerr72292@notify.bestcase.com

Melbalynn Fisher on behalf of Creditor U.S. Bank National Association

mfisher@ghidottiberger.com

Clarissa Pinheiro Schild Esq., on behalf of the Internal Revenue Service at 

clariss.schild@usdoj.gov

Neisi I Garcia Ramirez on behalf of Creditor U.S. Bank National Association

Neisi.GarciaRamirez@mccalla.com, FLBKECF@mccalla.com,mccallaecf@ecf.courtdrive.com

Keith S Labell on behalf of Creditor Deutsche Bank National Trust Company

klabell@rasflaw.com, klabell@rasflaw.com

Keith S Labell on behalf of Creditor Wells Fargo Bank, National Association

klabell@rasflaw.com, klabell@rasflaw.com

Office of the US Trustee

USTPRegion21.MM.ECF@usdoj.gov

Christopher P Salamone on behalf of Creditor Wells Fargo Bank, National Association

csalamone@rasflaw.com, csalamone@rasflaw.com

Robin R Weiner

ecf@ch13weiner.com, ecf2@ch13weiner.com

Case 20-12895-PDR Doc 133 Filed 05/27/21 Page 3 of 3