PH # 104248

UNITED STATES BANKRUPTCY COURT

FOR THE SOUTHERN DISTRICT OF FLORIDA

MIAMI DIVISION

In Re:

JOAQUINA RAPOSO,

Bk No.: 20-17186-AJC

Chapter 13

Debtor /

RESPONSE TO DEBTOR’S OBJECTION TO CLAIM NUMBER 7

Caliber Home Loans, Inc. (“Creditor”), through its undersigned counsel, files this 

Response to Debtor(s)’ Objection to Claim (Doc 20), and in support thereof avers as follows:

1. The Debtor(s) filed for Chapter 13 relief of June 30, 2020.

2. Creditor holds a Mortgage securing the property located at 2820 NW 174TH ST, 

MIAMI GARDENS, FL 33056-4035.

3. Creditor filed Proof of Claim number 7 (“the Claim”) on July 13, 2020. The 

Claim was amended on July 31, 2020.

4. The Debtor(s) filed an Objection to the Claim (“the Objection”) on August 6, 

2020. The basis for the Objection is the Debtor is making direct payments to the Creditor. The 

Debtor is seeking an Order allowing the Claim without distribution from the Chapter 13 Trustee.

5. Creditor has reviewed its records and maintains that the Claim was filed correctly. 

6. The Objection should be overruled due to the fact that Creditor’s Claim is 

properly filed and represents the secured claim on the Debtor(s)’ property as it stood at the time 

the instant Bankruptcy Petition was filed.

7. Creditor does not oppose entry of an order setting forth that the claim is allowed 

but shall not receive any distribution under the Chapter 13 Plan.

WHEREFORE, Respondent Caliber Home Loans, Inc. respectfully requests the Court 

overrule the Debtor(s)’ Objection to Claim Number 7 and for such other relief as is just and 

Case 20-17186-AJC Doc 23 Filed 08/10/20 Page 1 of 3
PH # 104248

proper.

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).

Date: August 10, 2020 /s/ Stefan Beuge, Esquire

Stefan Beuge, Esq., Florida Bar No. 68234 

Phelan Hallinan Diamond & Jones, PLLC 

2001 NW 64th Street

Suite 100

Ft. Lauderdale, FL 33309 

Tel: 954-462-7000 Ext. 56588 

Fax: 954-462-7001 

Email: stefan.beuge@phelanhallinan.com 

FLSD.bankruptcy@phelanhallinan.com

Case 20-17186-AJC Doc 23 Filed 08/10/20 Page 2 of 3
PH # 104248

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a true and correct copy of the foregoing, and any 

applicable exhibits attached thereto, has been served electronically, or routed for service by U.S.

Mail, to the following:

JOAQUINA RAPOSO 

2820 NW 174TH STREET

MIAMI GARDENS, FL 33056-4035

ROBERT SANCHEZ, ESQ.

355 W 49 ST. 

HIALEAH, FL 33012

NANCY K. NEIDICH, (TRUSTEE) 

WWW.CH13MIAMI.COM

POB 279806 

MIRAMAR, FL 33027

UNITED STATES TRUSTEE (SERVED ELECTRONICALLY) 

OFFICE OF THE UNITED STATES TRUSTEE 

51 SW FIRST AVENUE, ROOM 1204 

MIAMI, FL 33130

Date: August 10, 2020 /s/ Stefan Beuge, Esquire

Stefan Beuge, Esq., Florida Bar No. 68234 

Phelan Hallinan Diamond & Jones, PLLC 

2001 NW 64th Street

Suite 100

Ft. Lauderdale, FL 33309 

Tel: 954-462-7000 Ext. 56588 

Fax: 954-462-7001 

Email: stefan.beuge@phelanhallinan.com 

FLSD.bankruptcy@phelanhallinan.com

Case 20-17186-AJC Doc 23 Filed 08/10/20 Page 3 of 3