UNITED STATES BANKRUPTCY COURT 

SOUTHERN DISTRICT OF FLORIDA 

IN RE: Luis Perez Hernandez Case# 20-12738-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 need~ee court guideline 6) / 

~h 7 is $ LJ <;.1/ / CJ S may increase as documents not provided D Tax refund oc:rV" aluations L "'Other 

_ Good faith payment to unsecured creditors 

_Income understated per debtor's stubs$ taxes$ co-debtor stubs$ taxes$ ---

-Proof of household 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 100% 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 Agreement(s) 

Other: (c hecfliiP 0 H?flocf& J.if'11r'!d d~/i& 'S Ct;v l?fpt::>11.P f'ltf rlxfacJou( 

CVl SLn Si·ctlJti Llstoi a_.r d/ieU-p&j i'r1. fltl't'--· iv~,;-1 wuJ bul}llaltf/lfrHD Plan includes 100% Language 

. 2·9·· 

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 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 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 prose 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 20-12738-RAM Doc 28 Filed 05/05/20 Page 1 of 2
RE: Luis Perez Hernandez Case# 20-12738 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: 3117/20 

Tax returns: Corporate Tax Returns: 

LF 90 l IsF lir LF 10 

Plan does not fund properly 

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) 

{ 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: SPS 

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

IRS 

OTHER PLAN ISSUES: 

Real Estate FMV and Payoff: 

Non-Homestead Information Sheet: 

{ Vehicles FMV (NADA/Carmax), Reg and payoff: I 

Other: 

Bank Account Statements 3 months pre-petition 

Copy of check(s) and/or explanation: 

Tax Certificate (DE# Dept of Revenue 

Explanation ofwithdrawal(s): 

40 lK/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 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 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 prose 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 20-12738-RAM Doc 28 Filed 05/05/20 Page 2 of 2