Tom W. Sharp, ID #00791643

BLALACK & WILLIAMS, P.C.

4851 LBJ Freeway, Suite 750

Dallas, TX 75244

214/630-1916; 214/630-1112 (fax)

Attorneys for Nebraska Furniture Mart, Inc.

IN THE UNITED STATES BANKRUPTCY COURT

FOR THE NORTHERN DISTRICT OF TEXAS

(FORT WORTH DIVISION)

IN RE: ) CASE NO. 24-42560

)

MICHAEL A. PRITCHARD and )

JOI L. PRITCHARD )

Debtor(s) )

)

OBJECTION TO CONFIRMATION OF DEBTOR(S)’ CHAPTER 13 PLAN

TO THE HONORABLE JUDGE OF SAID COURT:

NOW COMES NEBRASKA FURNITURE MART, INC., the holder of a claim in the above

numbered and entitled case and files this, its Objection to Confirmation of Debtor(s)’s Proposed

Chapter 13 BankruptcyPlan, and as grounds therefore would respectfullyshow the Court as follows:

1. This court hasjurisdiction over this matter byvirtue of the jurisdiction conferred upon

it under 28 U.S.C. § 157 which characterizes this matter as a "core proceeding" arising in a case

under Title 11.

2. This creditor is the holder of claims in this case. The Debtor(s), whether one or more,

are indebted to Movant as follows: $6,165.92. 

3. Securing repayment of the above described indebtedness, the Debtor(s) gave this

creditor a security interest in furniture and merchandise as specified in Invoice No. 26631862,

67377548, 82285056, 82285049, 82282152, 82282160, and 83564251.

01006346.WPD Page 1 of 4

Case 24-42560-mxm13 Doc 17 Filed 10/01/24 Entered 10/01/24 13:47:16 Desc Main

Document Page 1 of 4
4. The Plan as proposed by the Debtor(s) fail to meet the provision of 11 U.S.C. §

1325(a)(3) of the United States Bankruptcy Code and has not been proposed in good faith. Movant

would show the court as follows:

 (a) The Debtor’s Chapter 13 Plan has not proposed to pay any amount owed to Nebraska

Furniture Mart as a secured claim. Of the items purchased by MICHAEL A. PRITCHARD and JOI

L. PRITCHARD within a year prior to the bankruptcy filing, there is a current balance owed of

$4,691.03.

(b) Of the items purchased by MICHAEL A. PRITCHARD and JOI L. PRITCHARD more

than a year prior to the Debtor(s) bankruptcy filing, Nebraska Furniture Mart, Inc. asserts a value of

$675.98.

(c). Nebraska Furniture Mart, Inc. asserts that it should be paid a secured claim/value

amount of $5,367.01, with the remaining balance being paid pro-rata with the other unsecured

creditors. 

(d). Additionally, no payments on the secured claim to NEBRASKA FURNITURE

MART INC., began until more than two years into the plan. NEBRASKA FURNITURE MART

INC. is entitled to set equal payments at an interest rate of no less than 9% pursuant to the Till case. 

WHEREFORE, Movant pays that this Court deny the confirmation of Debtor(s)’s Plan as

proposed unless and until Debtor(s) modify such Plan to correct the deficiencies cited herein.

Further, Movant prays for such other and further relief to which Movant may show itself justly

entitled.

01006346.WPD Page 2 of 4

Case 24-42560-mxm13 Doc 17 Filed 10/01/24 Entered 10/01/24 13:47:16 Desc Main

Document Page 2 of 4
 Respectfully submitted,

BLALACK & WILLIAMS, P.C.

Attorneys for Nebraska Furniture Mart, Inc.

BY: /s/ Tom W. Sharp 

Tom W. Sharp, ID #00791643

4851 LBJ Freeway, Ste. 750

Dallas, TX 75244

214/630-1916; 214/630-1112 (fax)

CERTIFICATE OF SERVICE

The undersigned certifies that a true and correct copy of the foregoing document was served

uponMichael Aaron Pritchard and Joi Lynn Pritchard, Debtor(s), 3926 WentwortthDrive,Arlington,

TX 76001; Jesse Schodrof Garcia, Attorney for Debtor, Bryeans & Garcia, PLLC,5001 S. Cooper

Street, Ste 209, Arlington, TX 76017; Tim Truman, Chapter 13 Trustee, 6851 N.E. Loop 820, Suite

300, N Richland Hills, TX 76180; U.S. Trustee, United States Trustee, Office of the U.S. Trustee,

1100 Commerce St., Room 976, Dallas, TX 75702; and upon all those requesting service below, all

by first class mail, address correction requested, or e-mail, on this 1st day of October, 2024.

/s/ Tom. W. Sharp 

Tom W. Sharp

01006346.WPD Page 3 of 4

Case 24-42560-mxm13 Doc 17 Filed 10/01/24 Entered 10/01/24 13:47:16 Desc Main

Document Page 3 of 4
CERTIFICATE OF CONFERENCE

The undersigned hereby certifies that on this 30 day of September, 2024.

____ 1(a) The creditor

XXX (B) The creditor’s attorney

XXX (C) made a good faith effort to negotiate a settlement of the dispute with debtor(s)’

counsel.

_____ (D) attempted to contact debtor(s)’ counsel, but debtor(s)’ counsel failed to respond to

our communication by the same time on the second business day after such communication.

XXX 2(a) The Motion is opposed.

____ (B) The Motion is unopposed.

/s/ Tom W. Sharp________________

Blalack & Williams, P.C.

01006346.WPD Page 4 of 4

Case 24-42560-mxm13 Doc 17 Filed 10/01/24 Entered 10/01/24 13:47:16 Desc Main

Document Page 4 of 4