UNITED STATES BANKRUPTCY COURT 

SOUTHERN DISTRICT OF FLORIDA 

In re: Case No:19-18883 RAM

Chapter 

VERNELL ROBINSON

Debtor /

OBJECTION TO CLAIM and CERTIFICATE OF SERVICE

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.

Pursuant to Bankruptcy Rule 3007 and Local Rule 3007-1, the debtor objects to 

the following claim filed in this case:

Claim # Name of Claimant Amount of Claim Basis for Objection and 

Recommended Disposition

 1 TD Bank by American see below

InfoSource as agent $2,982.60 U.S. Constitution 

Case 19-18883-RAM Doc 44 Filed 03/18/20 Page 1 of 3
 2 LVNV Funding LLC $3,081.04 see below 

 3 Quantum 3 Group as

agent for MOMA Trust LLC $ 539.18 see belos

The trustee realized debtor has a claim on account of personal bodily injury. Debtor 

then elected exemption under 11 U.S.C. §522 (11)(D). The Florida exemption statute 

contained in Florida Statute Section 222.20 exempts Florida residents from the federal 

exemption. THIS IS A VIOLATION OF THE UNITED STATES CONSTITUTION. Article 

1 section 8 # 4 provides Congress has the power to establish uniform Laws on the 

subject of Bankruptcies throughout the United States;

It is appears the inclusion into the Bankruptcy Code of 11 U.S.C. § 522 allowing states 

to limit federal exemptions is a violation of several rights that protect our citizens under 

the United States Constitution. The grant of power in section 522(b)(1) allowing state 

law that limits federal exemptions is unlawful as it discriminates against a person 

who has suffered bodily injury. Nor does the opt out provision of the bankruptcy code 

conform to any permissible method of deferral to state law. The grant of power to 

Congress to establish bankruptcy laws resulted from "the importance of preserving 

harmony, promoting justice, and securing equality of rights and remedies among the 

citizens of all the States.." ; 2 J. STORY. COMMENTARIES ON THE CONSTITUTION OF THE 

UNITED STATES § 1102-1115 (1873);

.

The effect of section 522 is to allow the states to control federal law-they are permitted 

to enact bankruptcy laws regulating interests under federal jurisdiction in violation of the 

bankruptcy and supremacy clauses of the Constitution. State laws which provide for 

less generous exemptions than those set forth in section 522 conflict with federal law, 

and thus should be ruled to be unconstitutional as it applies to this debtor

The debtor outside of student loan has little debt. The personal injury payment after 

attorneys fees and husband’s share should not be much money. The motivation of 

debtor’s attorney in this matter is not a fee for services because debtor is not able to 

pay a reasonable fee. The motivation is the loss of a federal exemption for personal 

bodily injury is a despicable injustice that should not be tolerated under the United

States Constitution. 

Each claim must be disallowed and barred for the above reasons. 

 “LS”

Lawrence M. Shoot 

Attorney for Debtor

4830 S.W. 92 Ave

Miami, FL. 33165

Tel: (305) 270-2110

Fla Bar # 112950

E mail: lshoot@bellsouth.net

Case 19-18883-RAM Doc 44 Filed 03/18/20 Page 2 of 3
CERTIFICATE OF SERVICE

I certify that the foregoing document has been furnished by CM/ECF to Christian 

Somodevilla, Esq. 2 S. Biscayne Blvd. Suite 2300 and all others receiving CM/ECF and the 

following by e mail on March 18, 2020.

TD Bank USA by American InfoSource as agent

4515 N. Santa Fe Ave. 

Oklahoma, City OK 73118

E mail: POC_AIS@americaninfosource.com

Resurgent Capital Services

P O Box 10587

Greenville SC 29603

E mail: askbk@resurgent.com

Quantum3 Group LLC agent for MOMA Trust

P O Box 788

Kirkland WA 98083

E mail: claims@quantum3group.com

“LS”

Lawrence M. Shoot

4830 S.W. 92 Ave

Miami, FL. 33165

Tel: (305) 270-2110

Fla Bar # 112950

E mail: lshoot@bellsouth.net

Case 19-18883-RAM Doc 44 Filed 03/18/20 Page 3 of 3