UNITED STATES BANKRUPTCY COURT

SOUTHERN DISTRICT OF FLORIDA

FORT LAUDERDALE DIVISION

IN RE:

ILEANA RAMUDO-TOWNSEND CaseNo.: 19-26381-SMG

Debtor / Chapter 13

MOTION TO VALUE AND DETERMINE SECURED STATUS OF LIEN ON

PERSONAL PROPERTY HELD BY BRIDGECREST

[2006 Lexus IS250, VIN# JTJBK262662010888]

IMPORTANT NOTICE TO CREDITORS:

THIS IS A MOTION TO VALUE YOUR COLLATERAL

This Motion seeks to value collateral described below securing the claim of the 

creditor listed below.

If you have not filed a proof of claim, you have until the later of the claims bar 

date or 21 days from the date this Motion was served upon you to file a proof 

of claim or you will be deemed to have waived the right to payment of any 

unsecured claim to which you might otherwise be entitled. [See Local Rule 

3015-3(A)(4)]

1. Pursuant to 11 U.S.C. §506, Bankruptcy Rule 3012, and Local Rule 3015-3, the debtor 

seeks to value personal property securing the claim of VW CREDIT INC (“Lender”).

2. (Select only one):

 X Lender’s collateral consists of a motor vehicle and is particularly described as 

follows:

Year and Model of motor vehicle: 2006 LEXUS IS250

Vehicle Identification Number (VIN #): JTJBK262662010888

Odometer reading: 145,000 Miles

 Lender’s collateral consists of a lien on personal property other than a motor vehicle 

and is particularly described as follows: 

3. At the time of the filing of this case, the value of the personal property is 

$ 3,500.00 as determined by BLACK BOOK VALUE.

4. The undersigned reviewed the docket and claims register and states (select only one):

Case 19-26381-SMG Doc 23 Filed 01/24/20 Page 1 of 2
 X Lender has not filed a proof of claim in this case. The trustee shall not disburse 

any payments to Lender unless a proof of claim is timely filed. In the event a proof 

of claim is timely filed, it shall be classified as a secured claim to the extent 

provided in paragraph 4, above, and as a general secured claim for any deficiency, 

regardless of the original classification in the proof of claim as filed. Lender’s 

secured claim shall be paid through the plan at 6.75 % and for a total of 

$ 3,843.60.

or

 Lender filed a proof of claim in this case, POC #1 in the mount of $_________. It 

shall be classified as a secured claim to the extent provided in paragraph 3, above, 

and as a general unsecured claim for any deficiency, regardless of the original 

classification in the proof of claim. Lender’s secured claim shall be paid through 

the plan at ____% and for a total of $_______.

5. The subject personal property may not be sold or refinanced without proper notice and 

further order of the court.

WHEREFORE, the Debtor respectfully requests an order of the Court (a) determining the 

value of the personal property in the amount asserted in this Motion, (b) determining the secured 

status of the Lender’s lien as stated above, (c) determining that any timely filed proof of claim is 

classified as stated above, and (d) providing such other and further relief as is just.

NOTICE IS HEREBY GIVEN THAT:

1. In accordance with the rules of this Court, unless an objection is filed with the Court 

and served upon the debtors, the debtors’ attorney, and the trustee at or before the 

hearing scheduled on this Motion, the value of the collateral may be established at 

the amount stated above without further notice, hearing, or order of the Court. 

Pursuant to Local Rule 3015-3, timely raised objections will be heard at the hearing 

scheduled on the Motion.

2. The undersigned acknowledges that this Motion and the notice of hearing thereon 

must be served pursuant to Bankruptcy Rule 7004 and Local Rule 3015-3 at least 

21 days prior to the hearing date and that a certificate of service must be filed when 

the Motion and notice of hearing thereon are served.

Submitted by:

VAN HORN LAW GROUP, P.A.

330 N. Andrews Ave., Suite 450

Fort Lauderdale, Florida 33301

(954) 765-3166

(954) 756-7103 (facsimile)

Chad@cvhlawgroup.com

By: /s/ Chad T. Van Horn, Esq.

Chad T. Van Horn, Esq.

 Fla Bar 64500

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