ALAW FILE NO. 19-025493 

UNITED STATES BANKRUPTCY COURT 

FOR THE SOUTHERN DISTRICT OF FLORIDA 

MIAMI DIVISION 

IN RE: 

JUDITH HOLMES 

aka JUDITH M. HOLMES

aka JUDITH M. HAYNES 

CASE NO 19-25604-RAM 

CHAPTER: 13 

 Debtor. 

__________________________/ 

RESPONSE TO DEBTOR’S OBJECTION TO CLAIM ON SHORTENED NOTICE 

[DE 29] 

Creditor, Nationstar Mortgage LLC d/b/a Mr. Cooper, (“Creditor”), by and through its 

undersigned counsel, hereby files this Response to Debtor’s Objection to Claim on Shortened 

Notice [DE 29] (the “Response”) and in support, states the following:

1. Creditor holds a secured mortgage on real property owned by Debtor located at 

17720 NW 41st Avenue, Miami Gardens FL 33055 (the “Subject Property). 

2. Creditor affirms that a timely Proof of Claim [Claim No. 1-1] (hereinafter the 

“Claim”) was filed on December 20, 2019, in the amount of $143,365.44 in secured mortgage debt 

and $18,598.14 in total debt. 

3. On March 5, 2020, Debtor filed an Objection to Claim on Shortened Notice [DE 

29] (hereinafter the “Objection”) alleging 1) the Creditor is demanding fees to which it is not 

entitled. Creditors Claim No, 1-1, lists Corporate Advances, to which the Debtor objects to the 

four entries of “posting costs” of $70.00, $70.00, $911.00 and $5.00 for a total of $1,056.00. 

Debtor also objects to the Foreclosure Sale Publication fee in the amount of $225.00, since the 

Debtor filed her Suggestion of Bankruptcy in the State Foreclosure case on December 27, 2019. 

Debtor proposes the amount of arrears to be reduced by $1,281.00 for a total arrears of $17,317.14. 

5. Creditor requests additional time to research the validity of the allegations set forth 

in the Debtor’s Objection. 

6. This matter has been scheduled for a hearing on April 7, 2020 at 9:00 AM, at C. 

Clyde Atkins U.S. Courthouse, 301 N Miami Ave Courtroom 4. 

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ALAW FILE NO. 19-025493 

7. Creditor reserves the right to supplement and/or amend this Response in the future. 

WHEREFORE, Nationstar Mortgage LLC d/b/a Mr. Cooper, respectfully requests that this 

Court allow additional time for the Creditor to address the allegations outlined in the Debtor’s 

Objection, and awarding any and all other relief that this Court deems just and appropriate. 

/s/ Ella Roberts 

Ella Roberts, Esq. 

FBN 0075943 

813-221-4743 EXT. 1611 

Albertelli Law 

Attorney for Secured Creditor 

PO Box 23028 

Tampa, FL 33623 

Facsimile: (813) 221-9171 

bkfl@albertellilaw.com 

Alternate: eroberts@albertellilaw.com

 

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ALAW FILE NO. 19-025493 

CERTIFICATE OF SERVICE 

 I HEREBY CERTIFY that a true and correct copy of the foregoing Response to Debtor’s 

Objection to Claim, was provided via electronic and/or regular U.S. Mail to the parties on the 

attached service list, this 13th day of March 2020.

SERVICE LIST 

Debtor

Judith Holmes 

17720 NW 41 Avenue 

Opa Locka, FL 33055 

Debtor’s Attorney 

Carolina A. Lombardi 

Legal Services of Greater Miami, Inc. 

4343 West Flagler Street #100 

Miami, FL 33134 

Trustee

Nancy K. Neidich 

www.ch13miami.com 

POB 279806 

Miramar, FL 33027 

U.S. Trustee

Office of the US Trustee 

51 S.W. 1st Ave. 

Suite 1204 

Miami, FL 33130 

/s/ Ella Roberts 

Ella Roberts, Esq. 

FBN 0075943 

813-221-4743 EXT. 1611 

Albertelli Law 

Attorney for Secured Creditor 

PO Box 23028 

Tampa, FL 33623 

Facsimile: (813) 221-9171 

bkfl@albertellilaw.com 

Alternate: eroberts@albertellilaw.com

Case 19-25604-RAM Doc 35 Filed 03/13/20 Page 3 of 3