IN RE: Manuel Lois Rodriguez 

UNITED STATES BANKRUPTCY COURT 

SOUTHERN DISTRICT OF FLORIDA 

Case# 21-10749-RAM 

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: 

Trustee reserves the right to raise additional objections until all requested documents are timely provided. 

_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 

_Jncome understated per debtor's stubs$ taxes$ _______ co-debtor stubs$ taxes$ __ _ 

_ JProofofhousehold size (government ID w/ address) and income of all adults disclosed on Sch J and CMI 

_Spouse's pay advices 

_Schedule J Expenses objectionable: D Provide Proof line D Line _____ _ 

D Object to Schedule J expenses but debtor(s) are over median or I 00% plan filed 

____ Expenses: documentation/calculation: CMI line ______________________ _ 

_ 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 on transfer SOFA undisclosed __ --, __ D provide Tolling A~re~ment(s) 

Other: \AJha+ Ni f pered .-}? OJCth of cd i.jeJ \?111 iiij1f1m-¥ 21). /!-mR. /\J5rn 6 P 

-~U,1(,te ClLcu~~~--lfLLlrf Li~- k1 rlk OUf1Ul~ (11;._1' me_ ( '/)U}d 1 i?l2IC111v.JJ1n cl' ~')!ell f): I\ 2....- - J, s dr IJ}v ( IMO m fd ( C.rYlJ.: -IS C10].,) Q af I(\ CU(l)l~ rat -

D Plan includes I 00% Language 

2 3 2021 1 

On or before 5 pm on , 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 i(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 13Documents.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. 

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 

Case 21-10749-RAM Doc 14 Filed 03/26/21 Page 1 of 2
RE: Manuel L. Rodriguez Case# 21-10749 RAM 

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

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

documents and thus objects as follows: Reviewed documents received prior to: 3/5/21 

./ Tax returns: 2020 ./ Corporate Tax Returns: 2019-2020 

Photo ID/SS card - Legible/Unredacted ./ LF 90 ./ LF 67 LF 10 

Plan does not fund properly 

Calculation e1Tors Missing months/amounts Inconsistent terms Plan form completed incorrectly 

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

./ 2016(13), SOFA #16 and Plan do not match Missing signed copy of the Attorney's Declaration 

Other provisions: /IVL 100% Lawsuit Gambling MMM 

Reaffirm, redeem or su1Tender 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 Tax Certificate (DE# Dept of Revenue 

IRS 

./ OTHER PLAN ISSUES: Plan pays up to month 36 and secured creditor under valuation section up to month 60. 

Amend section III. 132-1. creditor address to match poc #1 Santander and correct total paid in plan amount. 

Amend section VIII. to check "none" box. 

Real Estate FMV and Payoff: 

Non-Homestead Information Sheet: 

./ Vehicles FMV (NADA/Carmax), Reg and Payoff: 99 Kawasaki & 90 Mixer 

Other: 

./ Bank Account Statements 3 months pre-petition #4 706 (10/28-10/31) 

./ Copy ofcheck(s) and/or explanation: 11/9 #23161 $3000 

Explanation of withdrawal(s): 

401K/Retirement/Pension 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 suppoti 

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 

34 I - meeting of creditors. 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 AVOID DISMISSAL* 

Case 21-10749-RAM Doc 14 Filed 03/26/21 Page 2 of 2