UNITED STATES BANKRUPTCY COURT

SOUTHERN DISTRICT OF FLORIDA

MIAMI DIVISION

OBJECTION BY CREDITOR TO CONFIRMATION OF PLAN

COMES NOW Secured Creditor, Bank of America, N.A., by and through its undersigned 

counsel, and files this written objection to confirmation of Debtor(s)’s Proposed Chapter 13 Plan, 

pursuant to Bankruptcy Rules §3015(f), §9014 and all other applicable provisions of the 

Bankruptcy Code and as grounds therefor states:

1. On March 16, 2007, Debtor, Roy C Teran, executed and delivered a Note (“Note”) 

and a Mortgage (“Mortgage”) securing payment of the Note in the amount of 

$262,230.00 to Bank of America, N.A. The Mortgage was recorded on June 11, 

2007 in Book 25693 Page 1221 of the Public Records of Miami-Dade County, 

Florida. The loan was transferred to Secured Creditor which granted Secured 

Creditor a first lien on the real property located at 320 East 60th Street

Hialeah, Florida 33013 the (“Subject Property”) legally described as: 

2. The Debtor(s) has failed to file a Motion for Referral to Mortgage Modification,

however he has provided for mortgage mediation in the Plan. Secured Creditor 

requests that the Debtor(s) file his Motion for Referral to Mortgage Modification 

Mediation or amend the Plan to change Secured Creditor’s treatment.

Case No.: 20-23284-AJC

Chapter 13

Judge: A. Jay Cristol

IN RE: 

Roy Cesar Teran

aka NTera Investments

Debtor /

Case 20-23284-AJC Doc 51 Filed 01/26/21 Page 1 of 4
3. Secured Creditor has not consented Mortgage Modification Mediation or approved 

a loan modification at this time. 

WHEREFORE, Secured Creditor respectfully requests that this Court sustain the 

objections stated herein and deny confirmation of the Debtor(s)’s Plan, and for such other and 

further relief as this Court deems just and proper. 

DATED this 26th day of January 2021.

Respectfully submitted,

/S/ Seth Greenhill

___________________________________

SETH GREENHILL, ESQ.

Florida Bar # 97938

PADGETT LAW GROUP

6267 Old Water Oak Road, Suite 203

Tallahassee, FL 32312

(850) 422-2520 (telephone)

(850) 422-2567 (facsimile)

Seth.Greenhill@padgettlawgroup.com

Attorney for Creditor

Case 20-23284-AJC Doc 51 Filed 01/26/21 Page 2 of 4
CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished to 

the parties on the attached Service List by electronic notice and/or by First Class U.S. Mail on this 

26th day of January 2021:

/S/ Seth Greenhill

___________________________________

SETH GREENHILL, ESQ.

Florida Bar # 97938

PADGETT LAW GROUP

6267 Old Water Oak Road, Suite 203

Tallahassee, FL 32312

(850) 422-2520 (telephone)

(850) 422-2567 (facsimile)

Seth.Greenhill@padgettlawgroup.com

Attorney for Creditor

Case 20-23284-AJC Doc 51 Filed 01/26/21 Page 3 of 4
SERVICE LIST (CASE NO. 20-23284-AJC)

Debtor

Roy Cesar Teran

320 E 60 St

Hialeah, FL 33013

aka NTera Investments

Attorney for Debtor

Samir Masri

901 Ponce de Leon Blvd #101

Coral Gables, FL 33134

Trustee

Nancy K. Neidich

POB 279806

Miramar, FL 33027

U.S. Trustee

Office of the US Trustee

51 S.W. 1st Ave.

Suite 1204

Miami, FL 33130

Case 20-23284-AJC Doc 51 Filed 01/26/21 Page 4 of 4