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UNITED STATES BANKRUPTCY COURT 

SOUTHERN DISTRICT OF FLORIDA 

www.flsb.uscourts.gov 

In re: Julio Chirino Case No. 20-22980-AJC- 

 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 

13 Scolopax, LLC $3,801.73 

Basis for Objection and Recommended Disposition 

On or about 11/12/2021, Creditor filed an amended secured proof of claim in the amount of $3,801.73. account ending in 

1001 for a 2014 KW. This vehicle was a total loss and surrender to the insurance company. This amend proof of claim was 

filed after the bar date and therefor should be stricken and disallowed. 

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).) 

 

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LF-24 (rev. 12/01/09) Page 2 of 2

CERTIFICATE OF SERVICE 

I HEREBY CERTIFY that a true copy of the foregoing was sent on January 10, 2022 electronically to Nancy K. 

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

Scolopax, LLC Rocio Dizon 

2003 Western Avenue #340 2003 Western Avenue #340 

Seattle, WA 98121 Seattle, WA 98121 

Oak Harbor Capital, LLC 

2003 Western Avenue #340 

Seattle, WA 98121 

Via cerified mail 

Scolopax, LLC Registered Agent 

Jordan Morrison, Supervisor Corporation Service Company 

c/o Weinstein & Riley, P.S. 1201 Hays Street 

2001 Western Avenue #400 Tallahasse, FL 32301 

Seattle, WA 98121 

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 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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