UNITED STATES BANKRUPTCY COURT

SOUTHERN DISTRICT OF FLORIDA

FT. LAUDERDALE DIVISION

In re

Brenda Lee Wade-Lester 

CHAPTER 13

CASE NO. 19-17977-RBR

Debtor(s)

______________________________/

OBJECTION BY MTGLQ INVESTORS, LP TO CONFIRMATION

OF CHAPTER 13 PLAN FILED BY THE DEBTOR(S)

MTGLQ INVESTORS, LP("Creditor"), by the undersigned attorneys, objects to

confirmation of the Plan ("Plan") as proposed by the Debtor(s) and any future Plan(s) filed by the

Debtor(s) to the extent that such Plan or Plans contain the provision(s) to which this Objection is

directed. In support of this Objection, the Creditor states as follows: 

1. For value received, the Debtor(s) executed and delivered a Note and Mortgage

("Loan Documents") as evidence of indebtedness to Creditor. Said indebtedness is secured by

property more particularly described in the Mortgage as: REAL PROPERTY LOCATED: 3519

NW 32 ST LAUDERDALE LAKES, FL 33309, LEGALLY DESCRIBED AS: LOT 19,

BLOCK 28, LAUDERDALE LAKES NORTH GATE SECTION 6, ACCORDING TO THE

PLAT THEREOF, AS RECORDED IN PLAT BOOK 58, AT PAGE 33, OF THE PUBLIC

RECORDS OF BROWARD COUNTY, FLORIDA. ("Collateral"). Reasons for objection: 

Failure to Provide for Full Payment of Prepetition Arrearages

2. The Creditor will be filing a Claim which sets forth prepetition arrearages in the

approximate amount of $38,347.88, which are due and owing in regards to the loan.

3. The Plan fails to provide for payment of the full amount of these prepetition

arrearages through the Plan.

4. The Plan fails to comply with 11 U.S.C. §1325 (a)(5) in that it does not provide

adequate protection for Creditor's interest pursuant to 11 U.S.C. §361. In addition, Creditor does

not agree to such treatment through the Plan.

5. Creditor will withdraw this Objection in the event that the Plan is amended to

conform to the Creditor's proof of claim or otherwise satisfactorily address the issue(s) raised in

this Objection.

WHEREFORE, Creditor prays for the entry of an appropriate order denying confirmation

with respect to the Plan as proposed and any future Plan(s) filed by the Debtor(s) to the extent

that such Plan or Plans contain the provisions to which this Objection is directed.

Case 19-17977-SMG Doc 22 Filed 09/11/19 Page 1 of 2
Certification as to Admission to the Southern District Bar

I hereby certify that I am admitted to 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 court set forth in Local Rule 2090-1(A).

I hereby certify that if the above is a matter requiring a hearing rather than negative

notice, I have attempted to resolve the disputes involved with opposing parties prior to requesting

any hearing on the above Motion.

/s/ Jessica Hicks 

Jessica Hicks

Kass Shuler, P.A.

P.O. Box 800

Tampa, FL 33601

Phone: (813) 229-0900 Ext. 1465

Fax: (813) 229-3323

jhicks@kasslaw.com

Florida Bar No. 1003462

CERTIFICATE OF SERVICE

I HEREBY CERTIFY THAT a true and correct copy of the foregoing was furnished on

September 11, 2019, by U.S. Mail and/or electronic mail via CM/ECF to: Brenda Lee

Wade-Lester, 3519 NW 32 Street, Lauderdale Lakes, FL 33309; Matis H Abarbanel, Esq., 2150

S. Andrews Avenue 2nd Floor, Ft. Lauderdale, FL 33316; Robin R. Weiner, Trustee P.O. Box

559007, Ft. Lauderdale, FL 33355.

/s/ Jessica Hicks 

Jessica Hicks (x1465)

1911506/mlh

Case 19-17977-SMG Doc 22 Filed 09/11/19 Page 2 of 2