EXCEPTIONAL HEALTHCARE, INC.’S OBJECTION TO CONFIRMATION OF DEBTOR’S CHAPTER 13 PLAN Page 1 

Megan F. Clontz 

State Bar No. 24069703 

SPENCER FANE LLP 

5700 Granite Parkway, Suite 650 

Plano, TX 75024 

Telephone: (972) 324-0300 

Facsimile: (972) 324-0301 

Email: mclontz@spencerfane.com 

Aaron M. Kaufman 

State Bar No. 24060067 

GRAY REED 

1601 Elm Street, Suite 4600 

Dallas, Texas 75201 

Telephone: (214) 954-4135 

Facsimile: (214) 953-1332 

Email: akaufman@grayreed.com 

COUNSEL FOR EXCEPTIONAL HEALTHCARE, INC.

IN THE UNITED STATES BANKRUPTCY COURT 

FOR THE NORTHERN DISTRICT OF TEXAS 

DALLAS DIVISION 

In re: § 

§ Case No. 24-30209-mvl13 

Danielle Veronica Savoy § 

§ Chapter 13 

Debtors § 

EXCEPTIONAL HEALTHCARE, INC.’S OBJECTION 

TO CONFIRMATION OF DEBTOR’S CHAPTER 13 PLAN 

[Relates to Docket No. 12] 

TO THE HONORABLE MICHELLE V. LARSON, 

UNITED STATES BANKRUPTCY JUDGE: 

Exceptional Healthcare, Inc. (“Exceptional”), a creditor and party in interest in the 

above-styled and numbered case, hereby files its Objection (the “Objection”) to Confirmation of 

the Debtor’s proposed Chapter 13 Plan [Docket. No. 12] (the “Plan”), and in support thereof 

would respectfully show the Court as follows: 

BACKGROUND 

1. Danielle Veronica Savoy (“Debtor”) commenced the above-captioned Chapter 13 

case on January 25, 2024 (the “Petition Date”). Tom Powers is the duly appointed Chapter 13 

Trustee (the “Trustee”). 

2. Prior to the Petition Date, Debtor was employed by Exceptional as the Vice 

President of Finance from September 2021 through May 2022. Following termination of the 

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EXCEPTIONAL HEALTHCARE, INC.’S OBJECTION TO CONFIRMATION OF DEBTOR’S CHAPTER 13 PLAN Page 2 

Debtor’s employment, Exceptional determined that the Debtor issued unauthorized payments to 

herself from Exceptional’s bank account, failed to pay back a $10,000.00 loan issued to her by 

Exceptional, and made unauthorized purchases with Exceptional’s credit card. Before the 

Petition Date, Exceptional commenced a lawsuit against the Debtor, which action remains 

pending. See Exceptional Healthcare, Inc. v. Danielle Savoy, Cause No. DC-22-12898, 192nd

Judicial District Court of Dallas County, Texas. 

3. In her Schedules of Assets and Liabilities, see Docket No. 13, the Debtor has 

inaccurately listed a claim owed to Gray Reed (Exceptional’s counsel of record) in the 

undisputed, liquidated, non-contingent amount of $31,500. Contemporaneously with this 

Objection, Exceptional is filing a proof of claim seeking allowance of its claim in the amount of 

no less than $215,029.25. Exceptional reserves the right to seek a determination that such 

amounts are nondischargeable under 11 U. S. C. § 523(a). 

4. Debtor filed her Plan on February 12, 2024, proposing to pay a base plan amount 

of $15,000.00 in monthly installments of $250.00 over sixty (60) months, with direct payments 

to Ally Financial, Inc. and Huntington State Bank in the amounts of $33,130.34 and $22,704.18, 

respectively, to maintain possession of two vehicles. See Docket No. 12. 

5. A prehearing conference on confirmation of the Debtor’s Plan is set on April 4, 

2024, with a hearing on any unresolved pleadings to be held on April 4, 2024 at 2:00 p.m. CDT 

(the “Confirmation Hearing”). 

6. On March 15, 2024, the Trustee filed his Objection to Confirmation 

[Docket No. 24] (as supplemented by Docket No. 25, the “Trustee’s Objections”), based on the 

following: 

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EXCEPTIONAL HEALTHCARE, INC.’S OBJECTION TO CONFIRMATION OF DEBTOR’S CHAPTER 13 PLAN Page 3 

a. The Plan does not meet the best interests of creditors test as required by 11 U.S.C. 

§ 1325(a)(4); 

b. the plan does not meet the disposable income test as required by 11 U.S.C. 

§ 1325(b); 

c. the Plan is not feasible under 11 U.S.C. § 1325(a)(6) because the Debtor does not 

propose to pay sufficient income to satisfy the IRS’s claims and pay the minimum 

base calculated by the Trustee as $104,184.00; 

d. the Debtor has not complied with 11 U.S.C. §§ 1325(a)(9) and 1308; 

e. the Plan does not provide for the full payment, in deferred cash payments, of all 

claims entitled to priority under 11 U.S.C. § 507, per 11 U.S.C. § 1322(a)(2); 

f. the Plan has not been proposed in good faith per 11 U.S.C. §§ 1325(a)(3) or 

1325(a)(7); and 

g. the Debtor is already delinquent in making payments required under her Plan and 

may not be able to make all payments required thereunder. 

See Trustee’s Objections, Docket Nos. 24 & 25. 

OBJECTION AND JOINDER

7. Exceptional hereby joins the Trustee’s Objections for the reasons stated therein 

and requests that the Court deny confirmation of the Debtor’s Plan. 

8. Exceptional files this objection without limitation or waiver of any rights, claims, 

or defenses against the Debtor. 

9. Exceptional reserves its right to amend this Objection at any time prior to the 

Confirmation Hearing or prior to any continued setting of the Confirmation Hearing. 

WHEREFORE, Exceptional prays that the Court deny confirmation of the Debtor’s Plan, 

and for all such further relief as is just. 

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EXCEPTIONAL HEALTHCARE, INC.’S OBJECTION TO CONFIRMATION OF DEBTOR’S CHAPTER 13 PLAN Page 4 

Dated: April 2, 2024 /s/ Megan F. Clontz 

Megan F. Clontz 

State Bar No. 24069703 

Spencer Fane LLP 

5700 Granite Parkway, Suite 650 

Plano, TX 75024 

Telephone: (972) 324-0300 

Facsimile: (972) 324-0301 

Email: mclontz@spencerfane.com 

and 

Aaron M. Kaufman 

State Bar No. 24060067 

Gray Reed 

1601 Elm Street, Suite 4600 

Dallas, Texas 75201 

Telephone: (214) 954-4135 

Facsimile: (214) 953-1332 

Email: akaufman@grayreed.com 

COUNSEL FOR EXCEPTIONAL 

HEALTHCARE, INC. 

CERTIFICATE OF SERVICE 

I hereby certify that on April 2, 2024, a true and correct copy of the foregoing was served 

upon all parties receiving notice via the Court’s electronic transmission facilities and on the 

following parties by U.S. Mail. 

/s/ Megan F. Clontz

Megan F. Clontz 

Debtor 

Danielle Veronica Savoy, 

9246 Emberglow Lane, 

Dallas, TX 75243 

Debtor 

Danielle Veronica Savoy 

100 N Park Rd #1125 

Reading, PA 19610 

Debtor’s Attorney 

Leinart Law Firm 

10670 N Central Expressway, Suite 320 

Dallas, TX 75231 

Chapter 13 Trustee 

Thomas D. Powers 

105 Decker Ct, Suite 1150 

11th Floor 

Irving, TX 75062

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