UNITED STATES BANKRUPTCY COURT 

SOUTHERN DISTRICT OF FLORIDA 

WEST PALM BEACH DIVISION 

www.flsb.uscourts.gov

IN RE: Case No. 20-17662-MAM

Kristina M. Hawkins Chapter 13

Debtor. 

RESPONSE TO DEBTOR’S 

OBJECTION TO NOTICE OF MORTGAGE PAYMENT CHANGE 

RE: CLAIM NO. 2-1 NATIONSTAR MORTGAGE D/B/A MR. COOPER 

Secured Creditor, Nationstar Mortgage LLC d/b/a Mr. Cooper, hereby files this response 

to Debtor's Response and Objection to Notice of Mortgage Payment Change (Re: Claim No. 2-1 

Nationstar Mortgage d/b/a Mr. Cooper)(Doc. No. 44), and states: 

1. On July 15, 2020 Debtor filed this case under Chapter 13 of the Bankruptcy Code. 

2. On August 10, 2020 Mr. Cooper filed claim 2-1 which listed a secured claim in the 

amount of $307,649.72, a secured claim of $67,909.19 and regular monthly payments of 

$1,775.35. 

3. On February 12, 2021 there was an Agreed Order granting objection to claim 2-1 

which reduced the amount of prepetition fees from $17,620.80 to $12,000.00 only and allowed a 

reduced secured arrearage to $62,288.39 and a total secured claim of $302,028.92. 

4. Mr. Cooper filed a Notice of Mortgage Payment Change (Docket No. 43) on June 

21, 2021, changing the ongoing monthly mortgage payment from $1,775.35 to $2,006.72, because 

of a change in escrow. 

5. Debtor states in the objection that homeowner’s insurance has increased for the 

2021 year, but the Debtor pays homeowners insurance directly, as she always has. 

Case 20-17662-MAM Doc 47 Filed 06/29/21 Page 1 of 3
6. Debtor additionally states in the objection that the Debtor objects to any increase in 

her monthly mortgage payment as she is making the payment directly. 

7. Pursuant to the Second Amended Chapter Plan (Doc. No. 36) which was confirmed 

on February 19, 2021 (See Doc. No. 41), Nationstar Mortgage, LLC d/b/a Mr. Cooper is listed in 

Plan paragraph III A and is being paid $62,288.39 arrears and $1,775.35 regular monthly payments 

in months 1-60. 

8. Additionally, in the Second Amended Chapter 13 plan, the box in Second Amended 

Chapter 13 Plan paragraph III, A, for “Escrow is included in the Monthly Payments” is checked, 

while the boxes for “The Debtor(s) will pay taxes and insurance directly remain unchecked. 

Wherefore, the Notice of Mortgage Payment Change at Doc. No. 44 should be allowed 

with the increase from $1,775.35, to $2,006.72 as the loan is being paid in the plan and the increase 

is due to a change of escrow being paid in the confirmed Second Amended Chapter 13 Plan of 

Reorganization. 

/s/Steven G. Powrozek 

Steven G. Powrozek 

FL Bar 0316120 

Elizabeth Eckhart 

FL Bar 48958 

LOGS Legal Group LLP 

Attorney for Secured Creditor 

4630 Woodland Corporate Boulevard 

Suite 100 

Tampa, FL 33614 

Telephone: (813) 367-5813 

Fax: (813) 880-8800 

E-mail: logsecf@logs.com

Case 20-17662-MAM Doc 47 Filed 06/29/21 Page 2 of 3
CERTIFICATE OF SERVICE 

I hereby certify that I am admitted to the Bar of the United States District Court of the 

Southern District of Florida and I am in compliance with the additional qualifications to practice 

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

The undersigned certifies that on this 28th day of June, 2021, a copy of the foregoing 

response to objection to Notice of Payment Change was caused to be served via CM/ECF 

electronic filing or via First Class U.S. Mail upon the following: 

Kristina M. Hawkins 

4290 SW McClellen St 

Port Saint Lucie, FL 34953 

Shaun T. Plymale 

100 SW Albany Avenue, Suite 310 

Stuart, FL 34994 

Robin R Weiner 

POB 559007 

Fort Lauderdale, FL 33355 

United States Trustee 

51 SW 1st Ave 

Suite 1204 

Miami, FL 33130 

/s/Steven G. Powrozek 

Steven G. Powrozek 

FL Bar 0316120 

Elizabeth Eckhart 

FL Bar 48958 

LOGS Legal Group LLP 

Attorney for Secured Creditor 

4630 Woodland Corporate Boulevard 

Suite 100 

Tampa, FL 33614 

Telephone: (813) 367-5813 

Fax: (813) 880-8800 

E-mail: logsecf@logs.com

19-319392 

Case 20-17662-MAM Doc 47 Filed 06/29/21 Page 3 of 3