UNITED STATES BANKRUPTCY COURT

SOUTHERN DISTRICT OF FLORIDA

MIAMI DIVISION

www.flsb.uscourts.gov

In re: 

Chapter 11

 Case No.: 1:20-bk-10060-RAM

ROSA MARIA VILLAMAN,

Debtor.

_______________________________/ 

STIPULATION TO TREATMENT OF CLASS I OF 

DEBTOR’S SECOND AMENDED PLAN OF REORGANIZATION [D.E. 133]

THE PARTIES HERETO, SN SERVICING CORPORATION AS SERVICER FOR 

U.S. BANK TRUST, N.A., AS TRUSTEE FOR LSF8 MATER PARTICIPATION TRUST, 

hereinafter referred to as "Secured Creditor" through her attorney, and Rosa Maria Villaman, 

hereinafter referred to as "Debtor," through its undersigned attorney hereby enter into this 

Stipulation to resolve the issues raised in the Secured Creditor's Objection to Confirmation of 

Debtor’s Proposed Chapter 11 Plan and Disclosure Statement [D.E. 124]. Wherein the parties 

stipulate as follows:

1. The treatment of the allowed secured claim held by Secured Creditor on real 

property located at 2750 NW 169 Terr, Miami Gardens, FL 33056 in Class 1 of the Debtor’s 

Second Amended Plan Of Reorganization [D.E. 133] (the “Plan”) shall be modified as follows:

a. Secured Creditor’s Claim shall have a secured claim in the amount of $279,000.00 

and repaid at 4.75% over 30 years, the claim shall continue to be escrowed for 

property insurance. Secured Creditor shall have an unsecured claim in the amount of 

$35,274.44. Therefore, in addition to the monthly P&I payment of $1,455.40, the 

Debtor shall make a monthly escrow payment of $291.67 which includes the forced 

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placed insurance of $3,500.00 annually spread over 12 months. Said monthly escrow 

payment is subject to change periodically. Payments pursuant to this Stipulation and 

the Plan shall begin February 1, 2021. 

b. The Debtor shall be responsible for paying the taxes on the property directly to the 

taxing agency and must remain current on all post-petition taxes.

c. Secured Creditor is entitled to repayment of post-petition escrow advances totaling 

$6,979.70 which includes property taxes advancement and forced placed insurance

from January 3, 2020 to January 21, 2020. The Debtor shall pay these post-petition 

escrow advances in equal monthly installments of $116.33/mo for 60 months. 

d. Secured Creditor has relief from the automatic stay as to the Subject Property upon 

confirmation of Debtor’s Chapter 11 Plan. 

e. In the event of a default on payments to Secured Creditor under the terms of this 

stipulation prior to the entry of the confirmation order, Secured Creditor shall notify 

Debtor and Debtor’s counsel of the default in writing. Debtor shall have thirty (30) 

calendar days from the date of the written notification to cure the default. If Debtor 

fails to cure the default, Secured Creditor may lodge a declaration of default and 

order terminating the automatic stay and include that the 14-day stay as provided in 

FRBP 4001(a)(3) is waived. Upon entry of the order the automatic stay shall be 

terminated and extinguished for purposes of allowing Secured Creditor to notice, 

proceed with, and hold a trustee’s sale of the Subject Property, pursuant to applicable 

state law and without further Court Order or proceeding being necessary, including 

any action necessary to obtain complete possession of the Subject Property, including 

unlawful detainer.

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f. In the event of a default on payments to Secured Creditor under the terms of this 

stipulation after the entry of the confirmation order, Secured Creditor may proceed 

pursuant to the terms of the underlying Note and Deed of Trust, and state and federal 

law, to obtain complete possession of the Subject Property, including unlawful 

detainer, without further Court order or proceeding being necessary. Any and all 

default provisions included in Debtor’s Chapter 11 Plan are not applicable to Secured 

Creditor with regard to the Subject Property and Secured Creditor is only bound by 

the terms included in this stipulation.

2. The above modified terms shall be included in any confirmation order entered in 

this case. 

WHEREFORE, the Parties request that this Court include said stipulated terms in any 

Confirmation Order entered in this case. 

Dated this 2nd day of February, 2021.

Respectfully submitted,

By: /s/ Melbalynn Fisher 

Melbalynn Fisher, Esq.

GHIDOTTI | BERGER, LLP

Attorneys for Secured Creditor

1031 North Miami Beach Blvd

North Miami Beach, FL 33162

Telephone: (305) 501.2808

Facsimile: (954) 780.5578

Florida Bar No. 107698

mfisher@ghidottiberger.com

By: /s/ Elias Leonard Dsouza

Elias Leonard Dsouza Esq.

DCS LAW GROUP

Attorneys for Debtor

8751 W. Broward Blvd # 301

Plantation, FL 33324

Telephone: (954) 358-5911

Florida Bar No. 399477

dtdlaw@aol.com

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CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on February 2, 2021, I electronically filed the foregoing 

document with the Clerk of the Court using CM/ECF. 

I also certify that the foregoing document is being served this day, either via transmission

of Notice of Electronic Filing generated by CM/ECF or by first class U.S. Mail, upon

By: /s/ Melbalynn Fisher

 Melbalynn Fisher, Esq.

Debtor

Rosa Maria Villaman

2750 NW 169 Terr

Miami Gardens, FL 33056

Debtor’s Co-Counsel

Elias Leonard Dsouza, Esq.

8751 W. Broward Blvd # 301

Plantation, FL 33324

Debtors’ Co-Counsel

K Gabriel Gonzalez, Esq.

9000 Sheridan St # 95

Hollywood, FL 33024

Trustee

Nancy K. Neidich

www.ch13miami.com

POB 279806

Miramar, FL 33027

U.S. Trustee

Office of the US Trustee

51 S.W. 1st Avenue - Suite 1204

Miami, FL 33130

** All interested parties on the attached 

Service List.

U.S. Trustee’s Counsel

Steven D. Schneiderman, Esq.

Office of the US Trustee

51 SW 1 Ave #1204

Miami, FL 33130

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SERVICE LIST

Get Financed LLC

10590 N.W. 27th Street, Suite E104 

Doral, FL 33172-2109

Lavette D. Bell

c./o Sarah A. Cox 

600 Queensgrove Cres 

Virginia Beach, VA 23452-3820

US Bank Trust, N.A. 

c/o Robertson, Anschutz & Schneid

6409 Congress Avenue, Suite 100 

Boca Raton, FL 33487-2853

Capital One

P.O. Box 30285 

Salt Lake City, UT 84130-0285

Credit Control Corporation

P.O. Box 120568 

Newport News, VA 23612-0568

Credit One Bank

P.O. Box 98872 

Las Vegas, NV 89193

Enchanged Recovery Corp

8014 Bayberry Road 

Jacksonville, FL 32256-7412

Verizon Wireless

500 Technology Drive #550 

Weldon Spring, MO 63304

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