Exhibit Cover Sheet

Party submitting: NEWREZ LLC D/B/A SHELLPOINT MORTGAGE SERVICING Ex.#

4

Admitted: Yes or No (circle one)

Debtor: Samuel Fitzgerald Worrell

Case No.: 21-20622-PDR

Nature of Hearing

Docket No: [DE-26]

Secured Creditor’s Motion for Relief from Stay

United States Bankruptcy Court

Southern District of Florida

Dated _____________ , 2022.

By:_____________________, Deputy Clerk

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UNITED STATES BANKRUPTCY COURT

SOUTHERN DISTRICT OF FLORIDA

FORT LAUDERDALE DIVISION

IN RE:

Samuel Fitzgerald Worrell, 

Debtor

____________________________/

CASE NO.: 21-20622-PDR

CHAPTER 13

RESPONSE TO DEBTOR’S OBJECTION TO CLAIM NO. 1-1

NEWREZ, LLC d/b/a SHELLPOINT MORTGAGE SERVICING (“Secured Creditor”), 

by and through its undersigned attorney, hereby files its Response to Objection to Claim No. 1 

(“Objection”) (DE 30), and in support thereof states as follows:

1. Secured Creditor holds an interest in Debtors’ real property located at 7420 NW 41 

Court, Lauderhill, FL 33319.

2. Secured Creditor timely filed its Proof of Claim No. 1 on January 12, 2022 with a 

total debt of $598,576.01 and arrears totaling $197,844.29. 

3. Pursuant to Federal Rule of Bankruptcy Procedure 3001(f), a proof of claim (and, by 

extension, supplemental proof of claim) executed and filed in accordance with the 

Bankruptcy Rules “shall constitute prima facie evidence of the validity and amount of 

the claim.”

4. On January 31, 2022, Debtor filed an Objection, asserting allegations opposing 

Secured Creditor’s claim.

5. Secured Creditor’s Proof of Claim is valid in its total claim amount including arrears. 

Therefore, the Court should overrule the Objection.

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6. Secured Creditor’s Proof of Claim includes a valid Assignment of Mortgage. 

Therefore, any arguments that Secured Creditor lacks standing is moot. The Court 

should overrule the Objection.

7. Secured Creditor reserves the right to supplement its Response to Debtor’s Objection 

at any time before or at the hearing. 

WHEREFORE, Secured Creditor respectfully requests that this Honorable Court 

overrules Debtors’ objection and allows Secured Creditor's Proof of Claim as filed so as to 

preserve Creditor's Claim should any further amendments to Debtors’ Plan alter Creditor's 

treatment, and for such other and further relief as the Court may deem just and proper.

Robertson, Anschutz, Schneid, Crane & Partners, 

PLLC

Attorney for Secured Creditor

6409 Congress Ave., Suite 100

Boca Raton, FL 33487

Telephone: 561-241-6901

Facsimile: 561-997-6909

By: _/s/ April G. Harriott___________

April G. Harriott, Esquire

Email: aharitt@raslg.com

FL Bar Number: 37547

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CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on February 4, 2022, I caused to be electronically filed 

the foregoing with the Clerk of Court by using the CM/ECF system, and a true and correct copy 

has been served via CM/ECF or United States Mail to the following parties:

Samuel Fitzgerald Worrell 

7420 NW 41 Court 

Lauderhill, FL 33319

Robin R Weiner 

POB 559007 

Fort Lauderdale, FL 33355

Office of the US Trustee 

51 S.W. 1st Ave. 

Suite 1204 

Miami, FL 33130

Robertson, Anschutz, Schneid, Crane & Partners, 

PLLC

Attorney for Secured Creditor

6409 Congress Ave., Suite 100

Boca Raton, FL 33487

Telephone: 561-241-6901

Facsimile: 561-997-6909

By: _/s/ April G. Harriott___________

April G. Harriott, Esquire

Email: aharriott@raslg.com

FL Bar Number: 37547

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