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UNITED STATES BANKRUPTCY COURT 

SOUTHERN DISTRICT OF FLORIDA 

www.flsb.uscourts.gov

In re: Ruben Carrazana Case No. 20-20403-LMI

 Chapter 13

Debtor(s) /

OBJECTION TO CLAIM 

IMPORTANT NOTICE TO CREDITOR:

THIS IS AN OBJECTION TO YOUR CLAIM

This objection seeks either to disallow or reduce the amount or change the priority status of

the claim filed by you or on your behalf. Please read this objection carefully to identify which claim

is objected to and what disposition of your claim is recommended.

If you disagree with the objection or the recommended treatment, you must file a written 

response WITHIN 30 DAYS from the date of service of this objection, explaining why your claim

should be allowed as presently filed, and you must serve a copy to the undersigned

[attorney][trustee] OR YOUR CLAIM MAY BE DISPOSED OF IN ACCORDANCE WITH THE 

RECOMMENDATION IN THIS OBJECTION.

If your entire claim is objected to and this is a chapter 11 case, you will not have the right to

vote to accept or reject any proposed plan of reorganization until the objection is resolved, unless

you request an order pursuant to Bankruptcy Rule

3018(a) temporarily allowing your claim for voting purposes.

The written response must contain the case name, case number, and must be filed with the 

Clerk of the United States Bankruptcy Court.

301 North Miami Avenue, Room 150, Miami, FL 33128

Pursuant to Bankruptcy Rule 3007 and Local Rule 3007-1, Debtor objects to the following claim(s) 

filed in this case:

Claim Amount of

No. Name of Claimant Claim 

3 Bank of America / $191,764.48

Deutsche Bank National 

Trust Company As Trustee

Basis for Objection and Recommended Disposition

On or about November 16, 2020, Creditor filed a secured proof of claim in the amount of 

$191764.48 and an arrearage in the amount of $2,356.40 for the Debtor’s mortgage on his 

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homestead property for the account ending in 0121. Said Creditor will be paid outside the plan and 

directly by the Debtor. Debtor requests the claim be allowed as filed with no distribution from the 

Chapter 13 Trustee.

WHEREFORE the above-mentioned Debtor, respectfully requests that the Court grant the relief 

sought herein.

*Notwithstanding the requirements of Bankruptcy Rule 3007, up to five objections to claim may be 

included in one pleading. (See Local Rule 3007-1(C).)

 CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a true copy of the foregoing was sent on March 8, 2021 electronically 

to Nancy K. Neidich, Trustee and mailed via U.S. First-Class Mail, unless otherwise noted, to: 

Bank of America

450 American Street

Simi Valley, CA 93065-6285

Deutsche Bank National Trust Company 

As Trustee Bank of America, N.A.

P.O. Box 31785

Tampa, FL 33631-3785

Deutsche Bank National Trust Company

As Trustee Bank of America, N.A.

c/o Lindsey Savastano, Esq. 

One East Broward Blvd, Suite 111

Fort Lauderdale, FL 33301

Bank of America, N.A.

c/o Brian Moynihan, CEO

100 N. Tryon Street

Charlotte, NC 28255

Deutsche Bank National Trust Co.

c/o Eric Smith, CFO

60 Wall Street

NYC60-4006

New York, NY 10005 

CERTIFICATE OF ADMISSION

I HEREBY CERTIFY that I am a member of 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 

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Court set forth in Local Rule 2090-1(A). 

Respectfully Submitted: 

Robert Sanchez, P.A. 

Attorney for Debtor 

355 West 49th Street 

Hialeah, FL 33012

Tel. 305-687-8008

Fax. 305-512-9701

By: /s/ Robert Sanchez________________

 [X]Robert Sanchez, Esq., FBN#0442161

 

The party filing this objection to claim must file a certificate of service in accordance with Local Rule 

2002-1(F).

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UNITED STATES BANKRUPTCY COURT

SOUTHERN DISTRICT OF FLORIDA

www.flsb.uscourts.gov

In re: Ruben Carrazana Case No. 20-20403-LMI-

 

Chapter 13

Debtor(s) /

ORDER SUSTAINING DEBTOR’S OBJECTION TO CLAIM OF Bank of America

This matter having been considered without hearing upon the Debtor's Objection to Claim[s] of 

Bank of America [DE #____], and the objector by submitting this form order having represented that the 

objection was served on the parties listed below, that the 30-day response time provided by Local Rule 

3007-1(D) has expired, that no one listed below has filed, or served on the objector, a response to the 

objection, and that the relief to be granted in this order is the identical relief requested in the objection, 

and this court having considered the basis for the objection to the claim, it is

ORDERED that Debtor's objection to the following claim is sustained:

Claim holder Claim No.

Bank of America 3

Disposition: 

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*and the claim is stricken [without prejudice to Claimant to pursue its interest in the collateral]; or as 

duplicative; Claim #_____ is stricken and Claim #_____ is allowed; or

as a late filed claim and subject to further consideration upon the determination that sufficient funds exist 

to pay the claim in its order of priority;

and the claim shall be classified as a claim in the amount of $ .

###

Submitted by: 

Robert Sanchez, P.A., 

355 W 49 ST, 

Hialeah, FL 33012

(305) 687-8008

Robert Sanchez, P.A shall serve a copy of the signed order on all required parties and file with the court a 

certificate of service conforming with Local Rule 2002-1(F).

AGREED ORDER SUSTAINING DEBTOR’S OBJECTION TO CLAIM OF XXXX

This matter having come on to be heard at X____, on _____, on the Debtor's Objection to Claim[s] of 

XXXX [DE #____], this Court having noting agreement of parties and based upon the record, it is,

ORDERED: 

1. The Debtor's Objection to Claim No. XXX filed by ____, is SUSTAINED, in part. 

2. Claim No. _____ filed by ¬¬¬¬¬____, as an unsecured / secured claim, in the amount of $XXX, is 

STRICKEN and DISALLOWED.

3. Debtors' request for damages, fees and costs is DENIED WITH PREJUDICE.

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