UNITED STATES BANKRUPTCY COURT

SOUTHERN DISTRICT OF FLORIDA

MIAMI DIVISION

In re: Case No. 19-26391-LMI

NICOLAS VILLALOBOS Chapter 7

Debtor(s).

______________________________/

RESPONSE TO TRUSTEE’S OBJECTION TO

CLAIM NO. 4-1 FILED BY SPACE COAST CREDIT UNION

Creditor, SPACE COAST CREDIT UNION (“Space Coast”), by and through undersigned 

counsel, hereby files its Response to Trustee’s Objection to Claim No. 4-1 of Space Coast Credit 

Union [D.E. 31], and states as follows:

1. On December 6, 2019 (“Petition Date”), the Debtor, NICOLAS VILLALOBOS, 

filed a voluntary petition for relief under Chapter 7, Title 11 of the United States Bankruptcy Code. 

2. Space Coast holds a Note and Loan Documents on Debtor’s personal property, 

1990 Pursuit (the “Property”). 

3. On April 28, 2020, Space Coast timely filed a Proof of Claim in the total amount 

for the deficiency balance [Claim No. 4-1].

4. On June 23, 2020, in response to Trustee’s objection, Space Coast filed an amended 

Proof of Claim in the total amount for the deficiency balance after sale [Claim No. 4-2].

5. Proof of the deficiency balance after sale has been filed as an exhibit to the 

Amended Proof of Claim 4-2. 

6. Space Coast’s Proof of Claim was executed and filed in accordance with the Federal 

Rules of Bankruptcy Procedure and therefore constitutes prima facie evidence of the validity and

amount of the claim in accordance with Fed.R.Bankr.P. 3001(f). 

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7. Accordingly, Space Coast objects to the Trustee’s attempt to improperly strike 

Space Coast’s claim and respectfully requests the Court overrule the Trustee’s Objection.

8. Space Coast has retained the legal services of Blaxberg, Grayson, Kukoff & 

Forteza, P.A., and is indebted to said attorneys to pay them a reasonable attorneys’ fee. 

WHEREFORE, for the reasons stated herein, Space Coast Credit Union respectfully 

requests the Court overrule the Trustee’s Objection, allow Space Coast’s unsecured claim in the 

total amount of $8,399.44 [Amended Claim No. 4-2], and grant such other and further relief as the 

Court deems just and proper.

Dated: July 1, 2020

BLAXBERG, GRAYSON, KUKOFF & FORTEZA P.A. 

Attorneys for Space Coast Credit Union

25 SE Second Avenue, Suite 730

Miami, Florida 33131

Phone: (305) 381-7979 x 333

Fax: (305) 371-6816

Isabel.colleran@blaxgray.com 

By: /s/ Isabel V Colleran d

Isabel V Colleran, Esq.

Fla. Bar No. 450472

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CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on July 1, 2020, a true and correct copy of the foregoing was 

served via CM/ECF electronic transmission to those parties who are currently on the list to receive 

e-mail notice and service for this case, and by U.S. Mail to the following:

Nicolas Villalobos

Debtor

650 E 16th Place

Hialeah, FL 33010-3235

Robert Sanchez, Esq.

Counsel of Debtor

355 W 49 St.

Hialeah, FL 33012

Email: court@bankruptcyclinic.com

Robert A. Angueira

Trustee

16 SW 1st Avenue

Miami, FL 33130

trustee@rabankruptcy.com

Office of the US Trustee

U.S. Trustee

51 S.W. 1st Ave., Suite 1204

Miami, FL 33130

USTPRegion21.MM.ECF@usdoj.gov 

By: /s/ Isabel V Colleran d

Isabel V Colleran, Esq.

Fla. Bar No. 450472

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