LF-31 (rev. 06/04/21) Page 1 of 3

 UNITED STATES BANKRUPTCY COURT, SOUTHERN DISTRICT OF FLORIDA

www.flsb.uscourts.gov

CHAPTER 13 PLAN (Individual Adjustment of Debts)

■

Original Plan 

1st Amended Plan (Indicate 1st, 2nd, etc. Amended, if applicable)

Modified Plan (Indicate 1st, 2nd, etc. Modified, if applicable)

DEBTOR: JUANA ACOSTA MARTINEZ JOINT DEBTOR: CASE NO.: 21-19082-RAM

SS#: xxx-xx- 8860 SS#: xxx-xxI. NOTICES 

To Debtors: Plans that do not comply with local rules and judicial rulings may not be confirmable. All plans, amended plans 

and modified plans shall be served upon all creditors and a certificate of service filed with the Clerk pursuant to 

Local Rules 2002-1 (C)(5), 3015-1(B)(2), and 3015-2. Debtor(s) must commence plan payments within 30 days of 

filing the chapter 13 petition or within 30 days of entry of the order converting the case to chapter 13. 

 To Creditors: Your rights may be affected by this plan. You must file a timely proof of claim in order to be paid. Your claim may 

be reduced, modified or eliminated. 

 To All Parties: The plan contains no nonstandard provisions other than those set out in paragraph VIII. Debtor(s) must check one 

box on each line listed below in this section to state whether the plan includes any of the following:

The valuation of a secured claim, set out in Section III, which may result in a 

partial payment or no payment at all to the secured creditor Included ■ Not included

Avoidance of a judicial lien or nonpossessory, nonpurchase-money security interest, set 

out in Section III Included ■ Not included

Nonstandard provisions, set out in Section IX ■ Included Not included

II. PLAN PAYMENTS, LENGTH OF PLAN AND DEBTOR(S)' ATTORNEY'S FEE

A. MONTHLY PLAN PAYMENT: This Plan pays for the benefit of the creditors the amounts listed below, including trustee's 

fees of 10%, beginning 30 days from the filing/conversion date. In the event the trustee does not retain the full 10%, any unused 

amount will be paid to unsecured nonpriority creditors pro-rata under the plan:

1. $2,627.40 for months 1 to 10 ;

2. $2,460.73 for months 11 to 60 ;

B. DEBTOR(S)' ATTORNEY'S FEE: NONE PRO BONO

Total Fees: $4,500.00 Total Paid: $2,500.00 Balance Due: $2,000.00 

Payable $200.00 /month (Months 1 to 10 )

Allowed fees under LR 2016-l(B)(2) are itemized below:

Ch 13 Legal Fees $4500 plus filing fee. Amount paid $2500.00 balance of $2000 will be paid in CH 13 Plan

Applications for compensation must be filed for all fees over and above the Court's Guidelines for Compensation.

III. TREATMENT OF SECURED CLAIMS NONE

A. SECURED CLAIMS: NONE

[Retain Liens pursuant to 11 U.S.C. §1325 (a)(5)] Mortgage(s)/Lien on Real or Personal Property:

1. Creditor: West Bay Plaza Condominium Association c/o First Service Residential

 Address: 1688 West Avenue 

Miami Beach FL 33139

Last 4 Digits of 

Account No.: #408

Arrearage/ Payoff on Petition Date 65,681.44

Arrears Payment (Cure) $1,094.70 /month (Months 1 to 60 )

Regular Payment (Maintain) $746.73 /month (Months 1 to 60 )

Other:

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Debtor(s): JUANA ACOSTA MARTINEZ Case number: 21-19082-RAM

■ Real Property

■ Principal Residence

Other Real Property

Address of Collateral:

1688 West Ave. Apt. #408, Miami Beach FL 33139 

Check one below for Real Property:

Escrow is included in the regular payments

■ The debtor(s) will pay ■ taxes insurance directly

Personal Property/Vehicle 

Description of Collateral:

2. Creditor: Miami Dade County Tax Collector Property taxes 2017, 2018, 2020 Due to Certificate

 Address: 200 NW 2nd Avenue, 

Miami FL 33128

Last 4 Digits of 

Account No.: 0910

Arrearage/ Payoff on Petition Date 19394.10 (includes 0.25%) interest.

 * Property taxes $323.23 /month (Months 1 to 60 )

Other: * 2015, 2017, 2018, 2020, 2021 Property taxes 

Real Property

■ Principal Residence

Other Real Property

Address of Collateral:

1688 West Ave. Apt. #408, Miami Beach FL 33139 

Check one below for Real Property:

Escrow is included in the regular payments

■ The debtor(s) will pay ■ taxes insurance directly

Personal Property/Vehicle 

Description of Collateral: Property is under reverse mortgage

B. VALUATION OF COLLATERAL: ■ NONE

C. LIEN AVOIDANCE ■ NONE

D. SURRENDER OF COLLATERAL: ■ NONE

E. DIRECT PAYMENTS NONE

Secured claims filed by any creditor granted stay relief in this section shall not receive a distribution fom the Chapter 13 Trustee.

The debtor(s) elect to make payments directly to each secured creditor listed below. The debtor(s) request that upon 

confirmation of this plan the automatic stay be terminated in rem as to the debtor(s) and in rem and in personam as to any 

codebtor(s) as to these creditors. Nothing herein is intended to terminate or abrogate the debtor(s)' state law contract rights. 

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Name of Creditor Last 4 Digits of Account No. Description of Collateral (Address, Vehicle, etc.)

1.

Ameris Bank 

3 Corporate Square 

Atlanta GA 30329

3794 Debtor's son will continue paying for vehicle outside the plan 

2019 Chevrolet Trax 4D Utility 

VIN 3GNCJKSB7KL306842

2.

Pnc Bank 

Po Box 3180 

Pittsburgh PA 15230

2494 Debtor will keep paying for her vehicle 2018 Chevrolet 

Malibu VIN 1G1ZD4ST7JF229797 outside the plan.

3. Secretary of Housing and 

Urban Development 

Washington DC. 

451 Seventh St. SW 

Washington DC 20410

0127 Debtor will keep and maintain Homestead property located at 

1688 West Ave. Apt. #408, Miami Beach FL 33139 and paid 

all associated costs. this property is under reversed mortgage.

IV. TREATMENT OF FEES AND PRIORITY CLAIMS [as defined in 11 U.S.C. §507 and 11 U.S.C. § 1322(a)(4)] ■ NONE

V. TREATMENT OF UNSECURED NONPRIORITY CREDITORS NONE

A. Pay $50.00 /month (Months 11 to 60 )

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Debtor(s): JUANA ACOSTA MARTINEZ Case number: 21-19082-RAM

Pro rata dividend will be calculated by the Trustee upon review of filed claims after bar date.

B. ■ If checked, the Debtor(s) will amend/modify to pay 100% to all allowed unsecured nonpriority claims.

C. SEPARATELY CLASSIFIED: ■ NONE

VI. STUDENT LOAN PROGRAM ■ NONE

VII. EXECUTORY CONTRACTS AND UNEXPIRED LEASES ■ NONE

VIII. INCOME TAX RETURNS AND REFUNDS: ■ NONE

IX. NON-STANDARD PLAN PROVISIONS NONE

Nonstandard provisions must be set forth below. A nonstandard provision is a provision not otherwise included in the Local 

Form or deviating from it. Nonstandard provisions set out elsewhere in this plan are void.

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 Debtor will be paid in plan the property taxes as follows: 

2015 $2,686.82 + 2017 $2681.78 + 2018 $1716.85 + 2020 $6,183.28 (includes 0.25%) + 2021 $5,115.87 =Total $19,394.10 

Mortgage Modification Mediation 

/s/ Juana Acosta Martinez Debtor

JUANA ACOSTA MARTINEZ Date

11/4/2021

Attorney with permission to sign on 

Debtor(s)' behalf

Date

Joint Debtor

Date

PROPERTY OF THE ESTATE WILL VEST IN THE DEBTOR(S) UPON PLAN CONFIRMATION. 

 

I declare that the foregoing chapter 13 plan is true and correct under penalty of perjury. 

By filing this document, the Attorney for Debtor(s) or Debtor(s), if not represented by counsel, certifies that the wording and 

order of the provisions in this Chapter 13 plan are identical to those contained in Local Form Chapter 13 Plan and the plan 

contains no nonstandard provisions other than those set out in paragraph VIII.

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