UNITED STATES BANKRUPTCY COURT 

SOUTHERN DISTRICT OF FLORIDA - MIAMI DIVISION 

IN RE: 

ANGELA KUNKEL AKA ANGELA HELEN 

KUNKEL AKA ANGELA H KUNKEL AKA 

ANGELA HELEN WILLIAMSON AKA 

ANGELA H WILLIAMSON-KUNKEL AKA 

ANGELA WILLIAMSON-KUNDEL AKA 

ANGELA H WILLIAMSON AKA ANGELA 

HELEN WILLIAMSON-KUNKEL , 

CASE NO.: 21-19657-LMI 

CHAPTER 13 

 Debtor(s). 

______________________________________/

CREDITOR’ S RESPONSE TO MOTION TO SELL HOMESTEAD REAL ESTATE 

Subject property: 1120 VONPHISTER ST, KEY WEST, FL 33040 

COMES NOW, U.S. Bank Trust National Association, as Trustee for Treehouse Series V 

Trust (the "Creditor"), by and through undersigned counsel and files this its Response to the 

Debtor’s Motion to Sell Homestead Real Estate [D.E. 136] and states as follows: 

1. Debtor filed the instant Chapter 13 Bankruptcy Petition on October 6, 2021.

2. The Creditor holds a first mortgage security interest on real property located at 1120 

VONPHISTER ST, KEY WEST, FL 33040 recorded in Official Records Book 1902, 

Page 1764 in the public records of Monroe County, Florida on June 26, 2003.

3. Creditor filed its Proof of Claim 2 on October 25, 2021 providing a total debt as of 

petition filing date on $ 1,713,377.66, arrears of $ 881,800.30 and contractual payments 

in the amount of $6,826.09.

4. On September 23, 2022, the Debtor filed a Motion to Sell Homestead Real Estate [D.E. 

136]. Pursuant to the motion, the Debtor is proposing to sell the homestead property in 

which Creditor’s claim is secured. 

5. Creditor does not object to the sale of the subject property provided that any sale 

provide a full payoff as established by a current payoff statement of the claim as held 

by the Creditor. 

Case 21-19657-LMI Doc 141 Filed 10/27/22 Page 1 of 3
6. Creditor requires that any sale of the secured collateral be subject to receipt of a payoff 

statement provided by Creditor and that the claim by creditor is paid off in full and final 

satisfaction of the claim. 

7. In the event the sale does not take place, Creditor shall retain its respective lien for the 

full amount due under the terms of the loan. 

WHEREFORE, U.S. Bank Trust National Association, as Trustee for Treehouse Series 

V Trust, respectfully request the Debtor’s Motion to Sell Homestead real estate be granted subject 

to full payment of Creditor’s claim and that a payoff be obtained by Debtor to ensure the correct 

payoff amount is submitted and that the Court enter any and all relief it deems just and appropriate. 

 Diaz Anselmo & Associates, P.A. 

 Attorneys for Creditor (SHD No. 1692-177568) 

 PO BOX 19519 

 Fort Lauderdale, FL 33318 

 Phone: (954) 564-0071 

 Fax: (954) 564-9252 

 By: /s/ Ida A. Moghimi-Kian 

 Ida A. Moghimi-Kian 

 Florida Bar No.56395 

 IMoghimi-Kian@dallegal.com 

 

Case 21-19657-LMI Doc 141 Filed 10/27/22 Page 2 of 3
CERTIFICATE OF SERVICE 

I HEREBY CERTIFY that on this day, October 27, 2022, a copy of the foregoing was 

furnished electronically and/or via first class U.S. Mail upon: 

ANGELA KUNKEL AKA ANGELA HELEN KUNKEL 

AKA ANGELA H KUNKEL 

AKA ANGELA HELEN WILLIAMSON 

AKA ANGELA H WILLIAMSON-KUNKEL 

AKA ANGELA WILLIAMSON-KUNDEL 

AKA ANGELA H WILLIAMSON 

AKA ANGELA HELEN WILLIAMSON-KUNKEL 

1120 VONPHISTER STREET 

KEY WEST, FL 33040 

Debtor(s) 

TIMOTHY S KINGCADE, ESQ 

1370 CORAL WAY 

MIAMI, FL 33145 

Attorney for Debtor(s) 

 

NANCY K.NEIDICH 

PO BOX 279806 

MIRAMAR, FL 33027 

Trustee 

UNITED STATES TRUSTEE 

OFFICE OF THE U.S. TRUSTEE 

51 S.W. 1ST AVE. SUITE 1204 

MIAMI, FL 33130 

U.S. Trustee 

 

 Diaz Anselmo & Associates, P.A. 

 Attorneys for Creditor (SHD No. 1461-180824) 

 PO BOX 19519 

 Fort Lauderdale, FL 33318 

 Phone: (954) 564-0071 

 Fax: (954) 564-9252 

 By: /s/ Ida A. Moghimi-Kian 

 Ida A. Moghimi-Kian 

 Florida Bar No.56395 

 IMoghimi-Kian@dallegal.com 

Case 21-19657-LMI Doc 141 Filed 10/27/22 Page 3 of 3