Jason Sughrue

State Bar No. 24048150 

Allmand Law Firm, PLLC

860 Airport Freeway, Suite 401

Hurst, TX 76054

Telephone: (214) 265-0123

Facsimile: (214) 265-1979

Attorney for Debtor

IN THE UNITED STATES BANKRUPTCY COURT

FOR THE NORTHERN DISTRICT OF TEXAS

DALLAS DIVISION

IN RE:

BRITTANY RENEE RANSOM § CASE NO. 23-30856-13

§

Debtor, § CHAPTER 13

____________________________________§____________________________________

COOPERZADEH MGMT., LLC §

Movant, §

§

VS. § Preliminary Hearing on Motion

BRITTANY RENEE RANSOM § for Relief from Automatic Stay: 

residence

§

Respondent. §

DEBTOR'S ANSWER AND OBJECTION TO

MOTION FOR RELIEF FROM AUTOMATIC STAY

FILED BY COOPERZADEH MGMT., LLC

TO THE HONORABLE UNITED STATES BANKRUPTCY COURT:

COMES NOW RANSOM, BRITTANY RENEE ("Debtor" whether singular or 

plural) and requests of the Court that a hearing be scheduled on the subject matter and files this 

Debtor's Answer and Objection to Motion for Relief from Automatic Stay Filed by 

COOPERZADEH MGMT., LLC ("Movant"), and in support hereof would respectfully show the 

Court as follows:

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ELEMENT OF DEBTOR'S DEFENSE

1. There exists cause justifying the denial of Movant's Motion and requested action for the 

following reasons:

A. The property is necessary for the effective reorganization of the Debtor because it is 

the Debtor's residence

B. Debtor would show the Court that adequate protection is being paid by paying the 

indebtedness through Debtor's Confirmed Chapter 13 Plan of reorganization.

C. Debtor would show that the subject property is adequately insured to the extent 

necessary, proper, and sufficient to protect Movant's interest in the collateral.

D. Debtor would show the Court that any default may be cured within a reasonable time.

E. Debtor's Counsel will contact the Opposing Counsel to resolve this matter with an 

Agreed Order prior to the hearing date.

RIGHT TO AMEND OR SUPPLEMENT RESERVED

2. Debtor reserves the right to amend or supplement this Answer with additional 

information supported by Debtor's evidence, affidavit and/or amended answer.

PRAYER

WHEREFORE, PREMISES CONSIDERED, Debtor prays that a hearing be set in the 

instant matter, that Movant's Motion be denied in all respects and that the automatic stay 

pursuant to §362 of the United States Bankruptcy Code remain in full force and effect, and for 

such other and further relief to which the Debtor may show herself entitled.

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ALLMAND LAW FIRM, PLLC

/s/ Jason Sughrue

Jason Sughrue

State Bar No. 24048150 

860 Airport Freeway, Suite 401

Hurst, TX 76054

Telephone: (214) 265-0123

Facsimile: (214) 265-1979

Attorney for Debtor

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Document Page 3 of 4
CERTIFICATE OF SERVICE

The undersigned hereby certifies that on June 12, 2023, a true and correct copy of 

the foregoing was served on all parties in interest below.

DEBTOR(S):

Ransom, Brittany Renee

166 Yale Ave 

Red Oak, TX 75154

OPPOSING COUNSEL

Brandy Alexander

SBN: 24108421

2502 La Branch St.

Houston, Texas 77004

TRUSTEE:

Tom Powers

105 Decker Ct., 11th Flr., Ste. 1150

Irving, Texas 75062

U.S. TRUSTEE

Office of the U.S. Trustee

110 N. College Avenue, Suite 300

Tyler, Texas 75702

/s/ Jason Sughrue

Jason Sughrue

State Bar No. 24048150 

Case 23-30856-sgj13 Doc 34 Filed 06/12/23 Entered 06/12/23 12:54:49 Desc Main

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