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IN THE UNITED STATES BANKRUPTCY COURT

FOR THE DISTRICT OF KANSAS





CASE # 13-40698-7


IN RE:

LEIGHTY, JOHN WAYNE



Debtor.








TRUSTEE'S OBJECTION TO DEBTOR'S EXEMPTIONS

COMES NOW the Trustee, Darcy D. Williamson, and hereby enters the estate’s Objection to Exemptions

filed by the debtor. In support of her Objection, the Trustee alleges and states as follows:



1. The debtor exempted an Acorn IRA, Fidelity rollover IRA and a Keogh retirement program per K.S.A.

§ 60-2308 and § 74-4923. The Trustee has not received any documentation related to the IRAs and the Keogh

retirement program and cannot discern if they are properly exempt. The Trustee requests copies of the two IRAs and

the Keogh retirement program and transaction histories for each account.



2. The debtor exempted a 2004 Ford F-150 and a 2002 Honda Odyssey per K.S.A. § 60-2304(c). Per the

statute, the debtor is only allowed to exempt one means of conveyance regularly used for the transportation of the

person. Per the testimony at his 341 hearing, debtor stated he drives the 2002 Honda Odyssey and his non-filing

spouse drives the 2004 Ford F-150. The Trustee objects to the exemption of the 2004 Ford F-150.



WHEREFORE, the Trustee prays the Court for an Order sustaining this Objection and for all other further

and proper relief.


















































s/ Darcy D. Williamson
DARCY D. WILLIAMSON, Trustee
Attorney # 11337
510 SW 10th Avenue
Topeka KS 66612
(785) 233-9908
[email protected]














Case 13-40698 Doc# 18 Filed 09/10/13 Page 1 of 2

CERTIFICATE OF SERVICE

The undersigned does hereby certify that a true and correct copy of the foregoing TRUSTEE'S



OBJECTION TO DEBTOR'S EXEMPTION was filed electronically on September 10, 2013, with the United
States Bankruptcy Court for the District of Kansas, and shall be served on parties in interest via e-mail by the Court
pursuant to CM/ECF as set out on the Notice of Electronic Filing as issued by the Court and shall be served by U.S.
Mail, First Class, postage prepaid, on those parties listed below, and on those parties directed by the Court on the
Notice of Electronic Filing issued by the Court and as required by the Federal Rules of Bankruptcy Procedure and
the Local Rules of the United States Bankruptcy Court for the District of Kansas.













s/ Darcy D. Williamson
DARCY D. WILLIAMSON, Trustee
Attorney # 11337
510 SW 10th Avenue
Topeka KS 66612
(785) 233-9908
[email protected]

LEIGHTY, JOHN WAYNE, 26550 WAVERLY RD, PAOLA, KS 66071











































Case 13-40698 Doc# 18 Filed 09/10/13 Page 2 of 2