Reply to motion to dismiss ch 13 bankruptcy: Benjamin L. Jones-Norman

7/28/2019 Reply to motion to dismiss ch 13 bankruptcy: Benjamin L. Jones-Norman

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UNITED STATES BANKRUPTCY COURT

DISTRICT OF MINNESOTA

In Re: Benjamin Jones-Norman Case No. BKY 11-45314

Debtor.

REPLY TO MOTION OBJECTING TO CONFIRMATION OF CHAPTER 13 PLAN

AND FOR DISMISSAL OF CASE

TO: All parties in interest pursuant to Local Rule 9013-3.

1. Debtor requests an order of the court denying the relief sought by Jasmine Z.

Keller, chapter 13 trustee, for the reasons stated in this responsive motion.

2. Debtor has served and filed a modified chapter 13 plan for hearing at the next

available hearing date along with required supporting documents. Said modified plan is believed

by debtor to adequately address the objections raised by the trustee in her motion dated May 8,

2012 currently scheduled for hearing on 5-24-2012.

3. The debtor has received two pay stubs from his employment with Paramount

Pictures in Los Angeles, CA, and attorney for debtor has now provided copies of those pay stubs

to the trustees office in satisfaction of paragraph 7a of the trustees motion.

4. The debtor's budget includes a payment for a car loan that is in the name of

debtor's father as borrower and secured against the car (a 2011 Audi A5) debtor is driving. Both

the title of the car and the loan (city county credit union is the lender) are in debtor's father's

name. Debtor does not qualify for a loan or a lease of a suitable work vehicle. Debtor pays the

monthly car payment directly to city county credit union. The debtor's job with Paramount

Pictures requires him to have luxury style transportation because he is regularly responsible for

Case 11-45314 Doc 25 Filed 05/18/12 Entered 05/18/12 14:36:07 Desc MainDocument Page 1 of 5


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transporting and entertaining highly compensated and high demand "talent" such as graphic

designers, animation professionals, voice actors and actors for which the employer competes

with other film companies. The car was purchased slightly used, and a lesser car would not be

acceptable to fulfill the requirements of debtor's job. The debtors attorney has furnished the

trustee with a copy of the title for the car, which lists a security interest in favor of City County

Federal Credit Union, and lists debtors father as the sole owner of the vehicle. In addition a

copy of the check payable from the credit union to the dealer for the purchase of the vehicle was

provided to the trustee along with the loan disbursement document, showing the repayment

terms. This information should reasonably satisfy the concerns of paragraph 7b of the trustees

motion.

5. The debtors income verification and current budget relating to his relocation to

California, should reasonably satisfy the concerns of paragraphs 7d and 7e of the trustees motion.

The debtor is no longer paying the 401k loan on the 401k retirement plan administered at the

debtors former employment and this item has been removed from the debtors expense schedule

created in conformity with schedule J.

6. The debtor remains current in his plan payments and continuance of the trustees

motion herein to allow confirmation of the debtors modified plan dated 5-17-2012 will not

unduly prejudice the trustee, or creditors and will allow for the orderly administration of the

debtors case and payment to creditors in conformity with the bankruptcy code.

WHEREFORE, Debtor requests an Order from the Court denying the Trustees motions

herein.

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LANNERS & OLSON, P.A.

ATTORNEYS AT LAW

Dated: 4/7/2009 _/e/David C. Olson______David C. Olson, #169055

Attorney for Debtor

12805 Highway 55, Suite 102Plymouth, MN 55441

(763) 550-9892

VERIFICATION

I, David C. Olson, employed as attorney for debtor Benjamin Jones-Norman, debtor

herein, declare under penalty of perjury that the foregoing is true and correct according to thebest of my knowledge, information and belief.

Executed: 5-18-2012 /e/David C. Olson

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1993-201

1EZ-Filing,

Inc.

[1-800-998-2424]-FormsSoftwareOnly

United States Bankruptcy Court

IN RE: Case No.

Debtor(s)

Chapter

CERTIFICATE OF MAILING

The undersigned hereby certifies that a true copy of the following document(s):

was(were) mailed to all persons in interest at the addresses set forth in the exhibit which is attached hereto, by first class mail

postage prepaid, on this day of , .

District of Minnesota

11-45314

13Jones-Norman, Benjamin L

18th May 2012

response to motion

s/ David C. Olson

David C. Olson 169055Lanners and Olson, P.A.12805 Hwy. 55 Suite 102Plymouth, MN 55441(763) 550-9892 Fax: (763) [email protected]



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1993-201

1EZ-Filing,

Inc.

[1-800-998-2424]-FormsSoftwareOnly

Acura Financial Services2170 Point Blvd, Ste 100Elgin, IL 60123

American ExpressP O Box 0001Los Angeles, CA 90096

AsniP O Box 35171310 MLK DriveBloomington, IL 61702-3517

Capital One BankBankruptcy DepartmentP O Box 85520Richmond, VA 23285

Chase Home Finance, LLCP O Box 24696Columbus, OH 43224-0696

CitiP O Box 6241Sioux Falls, SD 57117

Direct TVQwest CommunicationP O Box 29080Phoenix, AZ 85038-9080

TCF Home Equity Line Of Credit US Department Of EducationP O Box 5609Greenville, TX 75403

Wells Fargo Wells Fargo Home MortgageP O Box 10388Des Moines, IA 50306


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