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UNITED STATES BANKRUPTCY COURT

SOUTHERN DISTRICT OF FLORIDA

FORT LAUDERDALE DIVISION

In re: Case No. 21-15007-PDR

Chapter 11

STAMATIKE GLARENTZOS,

SSN: xxx-xx-5816

Debtor.

______________________________________/

DEBTOR’S FIRST OBJECTION TO CLAIMS

IMPORTANT NOTICE TO CREDITORS:

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 stated in this objection,

explaining why your claim should be allowed as presently filed, and you must mail a copy to

the undersigned attorney 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.

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Pursuant to Bankruptcy Rule 3007 and Local Rule 3007-1, the debtor objects to the following claims

filed in this case:

Claim

No.

Name of Claimant Amount of

Claim

Basis of Objection and Recommended Disposition 

3 American Express

National Bank

$9,926.89 Statute of limitations for collection of this

debt under Fla. Stat. § 95.11 expired prior

to commencement of case. Recommended

claim disposition: Objection should be

sustained and the Claim should be

disallowed and stricken.

4 U.S. Bank Trust,

National Association,

as Trustee of Bungalow

Series IV Trust

c/o SN Servicing

Corporation

$1,584,306.04 On or about October 1, 2019, Debtor and

MTGLQ Investors c/o Rushmore Loan

Servicing entered into a settlement

agreement (Exhibit “A”) which required the

Debtor to payoff the mortgage loan for a

total due of $1,200,000 not later than

November 1, 2021, which was cause for the

dismissal of Debtor’s previous bankruptcy

case, The objection should be sustained and

the Claim should be allowed as secured in

the total sum of $1,200,000.

Certificate of Service

I CERTIFY that a true copy of the foregoing was served on all CM/ECF registered parties

via notice of electronic filing and by certified mail pursuant to FRBP 7004(h) and by regular first

class USPS carrier mail, postage fully prepaid, on all other interested parties as indicated on the

attached service list on August 9, 2021.

/s/ Peter Spindel 

PETER SPINDEL

Fla. Bar No. 816183

 Peter Spindel, Esq., P.A.

 8306 Mills Dr. #458

Miami, FL 33183-4838

Tel/Tex: 305.799.5724

email: peterspindel@gmail.com

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Via NEF21-15007-PDR Notice will be electronically mailed to:

Adisley M Cortez Rodriguez on behalf of U.S. Trustee Office of the US Trustee

Adisley.M.Cortez-Rodriguez@usdoj.gov

Christophal Calvin Hellewell on behalf of Creditor U.S. Bank Trust, N.A., as Trustee of the

Bungalow Series IV Trust

chellewell@ghidottiberger.com, bknotifications@ghidottiberger.com

Office of the US Trustee

USTPRegion21.MM.ECF@usdoj.gov

Peter D Spindel on behalf of Debtor Stamatike Glarentzos

peterspindel@gmail.com, peterspindelcmecf@gmail.com

By USPS mail:

Stamatike Glarentzos

932 N. Northlake Dr.

Hollywood, FL 33019

By certified mail, FRBP 7004(h):

U.S. Bank Trust National Association, as Trustee of Bungalow Series IV Trust

Attn: Andrew Cecere, CEO of US Bank Trust, NA

c/o SN Servicing Corporation

323 5th Streete

Eureka, CA 95501

American Express National Bank

Attn: Anré Williams, President

c/o Becket and Lee LLP

P.O. Box 3001

Malvern PA 19355-0701

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3882.2101

glarentzosS41.obj

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