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UNITED STATES BANKRUPTCY COURT 

SOUTHERN DISTRICT OF FLORIDA 

www.flsb.uscourts.gov

In re: Ana Cossio Case No. 21-12256-AJC-

 

 Chapter 13

Debtor(s) /

OBJECTION TO CLAIM 

IMPORTANT NOTICE TO CREDITOR:

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 of this objection, explaining why your claim

should be allowed as presently filed, and you mustserve a copy to the undersigned [attorney][trustee]

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.

301 North Miami Avenue, Room 150, Miami, FL 33128

Pursuant to Bankruptcy Rule 3007 and Local Rule 3007-1, Debtor objects to the following claim(s) 

filed in this case:

Claim Amount of

No. Name of Claimant Claim 

1 PHH Mortgage $194,531.97

Basis for Objection and Recommended Disposition

On or about April 6, 2021, Creditor filed a secured proof of claim in the amount of $194,531.97 and 

an arrearage in the amount of $3,901.08 for her homestead property located at 5030 E 2nd Avenue 

Hialeah, FL 33013-1412 for a Mortgage account ending in xxxxxx7397. The Debtor states that she 

is current with this claim and thus the Debtor requests the claim be allowed as filed with no 

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arrearage and no distribution from the Chapter 13 Trustee.

Claim Amount of

No. Name of Claimant Claim 

18 PORTFOLIO RECOVERY ASSOCIATES, LLC / $1,064.61

AMAZON

Basis for Objection and Recommended Disposition

On or about May 17, 2021, Creditor filed a general unsecured proof of claim in the amount of 

$1,064.61 for an Amazon credit card account ending in xxxxxx3670. The proof of claim attachment 

has a bill addressed to another address. The Debtor does not recognize this address or claim and 

states that the claim does not belong to her. Furthermore, the claim is not listed on Debtor’s 

schedules. Therefore, this claim should be stricken and disallowed. 

WHEREFORE the above-mentioned Debtor, respectfully requests that the Court grant the relief 

sought herein.

*Notwithstanding the requirements of Bankruptcy Rule 3007, up to five objections to claim may be 

included in one pleading. (See Local Rule 3007-1(C).)

 CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a true copy of the foregoing was sent on July 19, 2021 electronically to 

Nancy K. Neidich, Trustee and mailed via U.S. First-Class Mail, unless otherwise noted, to: 

PHH Mortgage

c/o Glen A. Messina, CEO

PO Box 5452

Mount Laurel, NJ 08054-5452

PHH Corporation

c/o Glen A. Messina, CEO

1 Mortgage Way

Mount Laurel, NJ 08054

PHH Mortgage Corporation

Attn: Bankruptcy Department

PO Box 24605

West Palm Beach, FL 33416-4605 

PHH Mortgage Corporation

c/o Robertson, Anschutz, Schneid, et. al. 

Attn: Keith Labell, Agent

6409 Congress Ave, Suite 100

Boca Raton, FL 33487

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PRA RECEIVABLES MANAGEMENT, LLC

c/o Graves, Christopher Barclay, President

130 CORPORATE BLVD.

NORFOLK, VA 23502

PORTFOLIO RECOVERY ASSOCIATES, LLC

c/o Steven D Fredrickson, President

120 CORPORATE BLVD., Suite 100

NORFOLK, VA 23502

PORTFOLIO RECOVERY ASSOCIATES, LLC

c/o Graves, Christopher Barclay, President

130 CORPORATE BLVD.

NORFOLK, VA 23502

PORTFOLIO RECOVERY ASSOCIATES, LLC

c/o CORPORATION SERVICE COMPANY

1201 HAYS STREET

TALLAHASSEE, FL 32301-2525

PRA RECEIVABLES MANAGEMENT, LLC

c/o Janel Decena, BK Rep. 

POB 41067

Norfolk, VA 23541

CERTIFICATE OF ADMISSION

I HEREBY CERTIFY that I am a member of the Bar of the United States District Court for the 

Southern District of Florida and I am in compliance with the additional qualifications to practice in this 

Court set forth in Local Rule 2090-1(A). 

Respectfully Submitted: 

JOSE A. BLANCO, P.A. 

By: /s/ Jose A. Blanco, Esq. FBN#062449

Attorney for Debtor 

355 West 49th Street 

Hialeah, FL 33012

Tel. 305-349-3463

Fax. 786-567-5057

 

The party filing this objection to claim must file a certificate of service in accordance with Local Rule 

2002-1(F).

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