UNITED STATES BANKRUPTCY COURT

SOUTHERN DISTRICT OF FLORIDA

MIAMI DIVISION

IN RE:

Ana S Cossio

aka Ana Cossio

aka Ana Sira Cossio,

Debtor.

________________________________/

CASE NO.: 21-12256-AJC

CHAPTER 13

RESPONSE TO OBJECTION TO CLAIM

COMES NOW, U.S. Bank National Association, as Trustee, successor in interest to

Bank of America National Association, as Trustee, successor by merger to LaSalle Bank

National Association, as Trustee for Lehman XS Trust Mortgage Pass-Through Certificates,

Series 2006-11 (“Secured Creditor”), by and through its undersigned attorney, hereby files its

Response to Objection To Claim (“Objection”) (DE # 31), and in support thereof states as

follows:

1. Debtor, Ana S Cossio (“Debtor”), filed a voluntary petition pursuant to Chapter

13 of the Bankruptcy Code on March 9, 2021.

2. Secured Creditor holds an interest in Debtor’s real property located at 5030 E 2nd

Avenue Hialeah, FL 33013-1412.

3. Secured Creditor filed its Proof of Claim, on April 6, 2021 as Claim Number 1.

4. Pursuant to Federal Rule of Bankruptcy Procedure 3001(f), a 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.”

Case 21-12256-AJC Doc 33 Filed 07/28/21 Page 1 of 3
5. On July 19, 2021, Debtor filed an Objection asserting they were current at the

time of this Bankruptcy.

6. Secured Creditor’s Proof of Claim, neither incorrect nor improper as filed, does in

fact show the Debtor was current on their payments on the date of petition. 

7. Secured Creditor is amenable to having this claim allowed with no distribution

from the Trustee. 

8. 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 this Honorable Court allows

Secured Creditor’s Proof of Claim as filed as to preserve Creditor’s Claim, and for such other

and further relief as the Court deems 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: 561-241-1969

By: /s/ Keith Labell

Keith Labell, Esq.

Email: klabell@raslg.com

Florida Bar No. 0109158

Case 21-12256-AJC Doc 33 Filed 07/28/21 Page 2 of 3
CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on July 28, 2021, 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:

Ana S Cossio

aka Ana Cossio

aka Ana Sira Cossio

5030 E 2nd Avenue

Hialeah, FL 33013-1412

Jose A Blanco

Jose A. Blanco, P.A.

355 W 49 ST

Hialeah, FL 33012

Nancy K. Neidich

www.ch13miami.com

POB 279806

Miramar, FL 33027

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: 561-241-1969

By: /s/ Keith Labell

Keith Labell, Esq.

Email: klabell@raslg.com

Florida Bar No. 0109158

Case 21-12256-AJC Doc 33 Filed 07/28/21 Page 3 of 3