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UNITED STATES BANKRUPTCY COURT

CENTRAL DISTRICT OF CALIFORNIA

In Re:

Debtor-in-Possession

))))))))))))))))))

Chapter 11

Case No. 2:15-BK-00000-VK

RESPONSE TO U.S. TRUSTEE’S MOTION TO

CONVERT OR DISMISS CASE WITH AN

ORDER DIRECTING PAYMENT OF

QUARTERLY FEES AND FOR JUDGMENT

THEREON

DECLARATION OF ATTORNEY

Date:

Time:

Crtrm:

TO: THE HONORABLE VICTORIA KAUFMANN, UNITED STATES BANKRUPTCY

JUDGE, OFFICE OF THE UNITED STATE TRUSTEE, SECURED CREDITORS, TWENTY

LARGEST UNSECURED CREDITORS AND ALL INTERESTED PARTIES:

-RESPONSE TO MOTION TO DISMISS OR CONVERT-- 1

Attorneys NameLaw FirmAddressAdressTel. (562) 000-0000; Fax. (562) 000-0000

Attorney for Debtor-in-Possession

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Debtor, Clients Name hereby responds to the United States Trustee’s Motion to Convert or

Dismiss the instant case and states as follows:

DEBTOR HAS FILED HER MONTHLY OPERATING REPORT FOR THE MONTH

OF JUNE AND IS CURRENT ON THE U.S TRUSTEE QUARTERLY FEES.

On July 16, 2015 the United States Trustee filed a Motion to Dismiss or Convert the instant case

based on failure of the debtor to file the June Monthly Operating Report and also based on the fact

that the primary asset of the debtor located at 14816 Wyandotte Street, Van Nuys, California, 91405

was foreclosed upon post-petition.

On July 21, 2015 Debtor filed her Monthly Operating Report for the Month of June and is now

current on her U.S Trustee Quarterly Fees.

POST-PETITION FORECLOSURE SALE

On June 2, 2015, Debtor filed the instant bankruptcy petition to stop the foreclose sale and reorganize

her debts through Chapter 11 Bankruptcy. The Debtor was surprised to learn that the real property

located at (Property Address), was sold by PLM Management in a non-judicial foreclosure sale on

June 3, 2015.

-RESPONSE TO MOTION TO DISMISS OR CONVERT-- 2

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Upon Investigation, she learned that Central Mortgage Company had acquired In Rem Relief from

Stay in an unrelated Bankruptcy Case; Re: John Smith Case No 1:15-bk-0000-SY based on a Grant

Deed which was received by the lender.

This Grant Deed was not signed by Mr. Clients Name, and was never recorded. Mr. Rosales had

consulted with a company known as Coastline and Associates and paid $3,750.00 for a loan

modification. Mr. Clients Name was not aware of the actions of the company and tried to contact

them to inquire if they prepared the Grant Deed. However, Coastline and Associates was no longer in

business.

On June 25, 2015 Debtor filed a Motion in the Case of John Smith to vacate the Order granting In

Rem Relief to Central Mortgage Company. At the hearing on July 28, 2015 the court denied the

Motion. At the time of filing of the instant case, Debtor was unaware of the activities of Coastline

and Associates nor did he consent to it. She was also unaware of the In Rem Relief obtained in the

Tashia Dee Lopez Case.

Based on the foreclosure sale of the only asset of the Debtor, the Debtor will not oppose the request

for dismissal of the instant case.

Dated: August 4, 2015 Law Firm

_____________________________________________

-RESPONSE TO MOTION TO DISMISS OR CONVERT-- 3

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Attorneys Name

Attorney for Debtor and Debtor-in-possession

DECLARATION OF ATTORNEY

I, (Attorneys Name), declare as follows:

1. I am an Attorney for the Debtor and as such, I have personal knowledge of the facts set forth

herein and or called as a witness. I could and would testify competently with respect thereto.

2. On June 2, 2015, my office filed a Chapter 11 Bankruptcy Petition for the debtor in order to

save her real property located at (insert property address) from a foreclosure sale and

reorganize her debts.

-RESPONSE TO MOTION TO DISMISS OR CONVERT-- 4

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3. Prior to the filing of the petition my office did its due diligence and did not find any issues.

4. On June 4, 2015, my office learned that the property was sold on June 3, 2015 by Central

Mortgage Company.

5. I contacted the attorney for Central Mortgage Company and was informed that Central

Mortgage Company had obtained In Rem Relief from Stay in an unrelated Bankruptcy Case

Re: Tashia Dee Lopez, Case No 1:15-bk-00000-SY based on a Grant Deed which was

received by the lender.

I declare under penalty of perjury under the Laws of the State of California that the

foregoing is true and correct.

Dated: August 4, 2015 ____________________

Attorneys Name

-RESPONSE TO MOTION TO DISMISS OR CONVERT-- 5