LF-70 (rev. 12/01/09) 

UNITED STATES BANKRUPTCY COURT 

 SOUTHERN DISTRICT OF FLORIDA

www.flsb.uscourts.gov

 

IN RE: CASE NO. 19-24331-BKC-JKO 

 CHAPTER 13 

RALPH LEVI SANDERS, JR. 

__________________________/ 

 

OBJECTION TO CLAIM ON SHORTENED NOTICE

AND CERTIFICATE OF SERVICE OF COURT-GENERATED NOTICE OF HEARING 

UPON FILING OF INSTANT MOTION

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. Upon the filing of this objection an expedited hearing on this 

objection will be scheduled on the date already scheduled for the confirmation 

hearing in accordance with Local Rule 3007-1(B)(2).

Pursuant to Bankruptcy Rule 3007 and Local Rule 3007-1(B)(2), the Debtor objects 

to the following claim filed in this case: 

Claim No. Name of Claimant Amount of Claim Basis for Objection and Recommended 

Disposition

 3-1 Department of the 

Treasury – Internal 

Revenue Service

$42,307.92 The creditor filed an unsecured priority

claim in the amount of $14,677.32 for 

an unfiled 2016 tax return. The Debtor 

states that this return has been filed. 

Sustain Objection and limited priority 

claim to $214.88 for 2012 taxes owing. 

The undersigned acknowledges that this objection and the notice of hearing for this 

objection will be served on the claimant and the debtor at least 14 days prior to the 

confirmation hearing date and that a certificate of service conforming to Local Rule 2002-

1(F) must be filed with the court when the objection and notice of hearing are served. 

CERTIFICATE OF SERVICE AND COMPLIANCE 

WITH LOCAL RULES 3015-3(A)(1) AND 9073-1(D)

 I hereby certify that a copy of this Objection and the Notice of Hearing Generated by 

the Court upon filing of instant motion will be served pursuant to Bankruptcy Rule 7004 on 

the Chapter 13 trustee and the following affected parties in the manner described below on 

this 2nd day of February, 2020 and that I have conferred with opposing counsel in an 

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LF-70 (rev. 12/01/09) 

attempt to resolve these issues before requesting this hearing: 

I hereby certify that I am admitted to 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 as set forth in local rule 910(d)(1) and (2). 

Served Upon:

VIA CM/ECF:

Office of the US Trustee 

USTPRegion21.MM.ECF@usdoj.gov 

Robin R Weiner 

ecf@ch13weiner.com;ecf2@ch13weiner.com

VIA U.S. MAIL:

Internal Revenue Service 

PO Box 7346 

Philadelphia, PA 19101-7346 

Internal Revenue Service 

7850 SW 6 Ct. 

M/S 5730 

Jacksonville, FL 32202 

ATTN: Jorge Luciano, Bankruptcy Specialist 

Dated: February 2, 2020 LAW OFFICES OF MICHAEL H. JOHNSON 

Attorneys for Debtor(s) 

3601 W. Commercial Blvd, Ste 31 

Ft. Lauderdale, FL 33309 

(954) 535-1131 

By:_/s/ Michael H. Johnson_____ 

 Michael H. Johnson 

 Florida Bar No. 0149543 

I HEREBY CERTIFY THAT I AM ADMITTED TO 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). 

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