IN RE: Armando Mohedano 

UNITED STATES BANKRUPTCY COURT 

SOUTHERN DISTRICT OF FLORIDA 

Case# 21-10748-AJC 

TRUSTEE'S NOTICE OF DEFICIENCY FOR CONFIRMATION (legal issues: 341) 

The Trustee reviewed this case for the meeting of creditors and found the following deficiencies from the Trustee's 

Notice of Required Documents, prior deficiencies, and legal issues and thus objects as follows: 

Tr/tee reserves the right to raise additional objections until all requested documents are timely provided. 

L Objection to Exemption (specifics to be filed) to be heard with confirmation at 1 :30 pm not at 9:00 am 

_Fee application needed (see court guideline 6) 

Ch 7 is may increase as documents not provided D Tax refund D Valuations D Other 

_ Good faith payment to unsecured creditors 

Zrncome understated per debtor's stubs$ taxes$ LSpWiVO co-debtor stubs$ taxes$ __ _ 

·-- Proofofhousehold size (government ID w/ address) and income of all adults disclosed on Sch J and CMI 

_Spouse's pay advices 

_ Sched~xpenses objectionable: D Provide Proof line D Line ___ _ 

/ · Object to Sch_edule J exp~nses but ~ebtor(s are over median or 100% plan ~led 

!L'Expenses: documentat1on/calculat1on: CMI !me , I (! I Skol }1p . 2 ~J!JJ? fo( P,&11 '. t . (\ ' . . .. . . . !\ ) ·- . . I . I . . 

_Plan does not pay debtor's calculation of disposable income CMI/DI x 60 = $ ____ _ 

D Pending income/expenses issues D Trustee believes D/I is understated (estimated D/I $ ____ _ 

D Feasibility or D plan payments reduce month ___ or D balloon payment 

_Plan does not conform to Applicable Commitment Period < 36 months< 60 months 

Info Qn transfer ~nPA undisclosed _ D provide Tolling Agreement(s) 

Other: · 

D Plan includes 100% Language 

On or before 5 pm on ::,

9.. , all documents/explanations with documented back up must be 

received/filed to avoid dismissal. If documents are not timely filed/received by the trustee, the trustee may seek 

dismissal of this case. IMPORTANT NOTICE: The debtor or debtor's attorney must appear at the confirmation 

hearing even if they agree to the recommendation. The debtor may still be dismissed for failure to fund the plan if they 

are delinquent in payments. Attorneys must upload all documents to Trustee through /3Documents.com. 

THE PRO SE DEBTOR OR DEBTOR'S ATTORNEY MUST CONTACT THE TRUSTEE'S OFFICE AND SPEAK 

TO AN ATTORNEY BEFORE 2PM ONE BUSINESS DAY PRIOR TO THE CONFIRMATION HEARING TO 

RESOLVE ALL OUTSTANDING ISSUES. 

1 hereby certify that a true and correct copy of the foregoing was served through ECF on the debtor's attorney 

or by U.S. First Class pre-paid Mail on the pro se debtor on the same day filed with the Court. 

Submitted by 

NANCY K. NEIDICH, ESQ, STANDING CHAPTER 13 TRUSTEE P.O. BOX 279806, MIRAMAR, FL 33027 

Case 21-10748-AJC Doc 18 Filed 03/26/21 Page 1 of 2
RE: Armando Mohedano Case# 21-10748 AJC 

TRUSTEE'S NOTICE OF DEFICIENCY FOR CONFIRMATION AND RECOMMENDATION (Pre 341) 

The Trustee reviewed this case for the meeting of creditors and fonnd the following deficiencies from the Trustee's letter requesting 

documents and thus objects as follows: Reviewed documents received prior to: 3/4/21 

./ Tax returns: 2020 

Photo ID/SS card - Legible/Unredacted 

Plan does not fund properly 

Corporate Tax Returns: 

LF 90 LF 67 LF 10 

Calculation errors Missing months/amounts Inconsistent terms Plan form completed incorrectly 

Attorney fee itemization or Fee Application needed (see court guideline 6) 

Missing 2016(B) Missing signed copy of the Attorney's Declaration 

Other provisions: IVL 100% Lawsuit Gambling MMM 

Reaffirm, redeem or surrender Sch D or G creditor: 

MMM Motion not filed Valuation motion not filed Lien Avoidance motion not filed 

Priority debt on Schedule E not in plan: 

Creditor in Plan is not listed in Schedules or has not filed a POC: 

Creditor paid through the Plan has not filed a POC: 

Object or Conform to Proof of Claim: Miami-Dade County 

IRS 

OTHER PLAN ISSUES: 

Real Estate FMV and Payoff: 

./ Non-Homestead Infonnation Sheet: JAMAICA 

Vehicles FMV (NADA/Carmax), Reg and Payoff: 

Other: 

Tax Certificate (DE# 

./ Bank Account Statements 3 months pre-petition #1809-01/07 (1/7-1/28/2021) 

./ Copy of check(s) and/or explanation: #98 $1930 

Explanation ofwithdrawal(s): 

Dept of Revenue 

ICMA-Retirement Stmt Annuity Life Insurance Policy 

Domestic Support Obligation form complete with info: name, address and phone 

./ Wage deduction order or Motion to waive 

BDQ & attachments Profit/loss Balance Sheet 

Business Bank statements and checks 3 months pre-petition 

Affidavit of support 

Trustee reserves the right to raise additional objects until all requested documents are timely provided. This deficiency is limited to 

missing documents only. The Trustee will file a Notice of Deficiency with additional document requested and legal issues raised after the 

341 - meeting ofereditors. I hereby certify that a true and correct copy of the foregoing was served through ECF on the debtor's 

attorney or by U.S. First Class pre-paid Mail on the pro se debtor on the same day filed with the Court. 

Submitted by NANCY K. NEIDICH, ESQ, STANDING CHAPTER 13 TRUSTEE P.O. BOX 279806, MIRAMAR, FL 33027 

*DOCUMENTS MUST BE RECEIVED OR FILED AND ISSUES ADDRESSED AT LEAST FOURTEEN DAYS PRIOR TO EACH 

CONFIRMATION HEARING TO A VOID DISMISSAL* 

Case 21-10748-AJC Doc 18 Filed 03/26/21 Page 2 of 2