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Case 12-28809 Doc 67 Filed 02/20/13 Page 1 of 4

IN THE UNITED STATES BANKRUPTCY COURT

FOR THE DISTRICT OF MARYLAND

Located in Greenbelt

IN RE

MONICA PATRICIA MCGINLEY
A/K/A MONICA STEYSKAL

Case No. 12-28809-TJC
Chapter 13

Motion No.

Debtor
CENTRAL MORTGAGE COMPANY
801 John Barrow Road
Suite 1
Little Rock, AR 72205

Movant
v.

DIANNE M. FAVRE
18933 Treebranch Terrace
Germantown, MD 20874

and

MONICA PATRICIA MCGINLEY
a/k/a Monica Steyskal
19710 Maycrest Way
Germantown, MD 20876

Respondents

MOTION FOR RELIEF FROM AUTOMATIC STAY

COMES NOW, Central Mortgage Company, its successors and/or assigns,
movant, by its attorneys, Mark D. Meyer, Esq., and Rosenberg & Associates, LLC,
and respectfully represents as follows:

1. Jurisdiction is based on 11 U.S.C. Section 362(d)-(f) and 1301.

2. On or about October 17, 2012, Monica Patricia McGinley a/k/a Monica
Steyskal ("Debtor") filed a Voluntary Petition in the Court under Chapter 13 of the
Bankruptcy Code.

3. Nancy Grigsby is the Chapter 13 trustee of the Debtor's estate.

4. Dianne M. Favre ("Co-Debtor") is a co-debtor on this Note.

5. At the time of the initiation of these proceedings, the Debtor owned a

MARK MEYER

DC BAR 475552
MD BAR 15070
VA BAR 74290

ROSENBERG &

ASSOCIATES, LLC

7910 WOODMONT AVENUE

SUITE 750

BETHESDA, MARYLAND 20814

(301) 907-8000

FILE NUMBER: 39621

Case 12-28809 Doc 67 Filed 02/20/13 Page 2 of 4

parcel of fee simple real estate improved by a residence with a legal description of
"Lot 52, Block lettered "A", "GERMANTOWN VIEW" among the Land Records of
Montgomery County, Maryland" also known as 18933 Treebranch Terrace,
Germantown, MD 20874 (hereinafter "the subject property").

6. The subject property is encumbered by a Deed of Trust securing the note,
which is currently held by the movant. The Promissory Note has been transferred
from BankUnited, FSB to Central Mortgage Company. The documents evidencing
the movant's security interest are attached hereto.
7. The total amount due under the Deed of Trust securing the Movant as of
February 20, 2013, including attorney's fees and court costs, is approximately
$278,884.88.

8. The Debtor is in default under the Deed of Trust, and the Movant has
accelerated the entire balance of the Note and Mortgage and interest continues to
accrue.

9. The Debtor has not made post-petition payments for the months of
January 1, 2011 - February 1, 2013, and equity in the Debtor's residence is
dissipating.

10. The Movant lacks adequate protection of its interest in the subject
property.
11. The Movant has been and continues to be irreparably injured by the stay
of Sections 362 and 1301 of the Bankruptcy Code, which prevents the Movant from
enforcing its rights under the Note and Deed of Trust.

12. Cause exists for lifting the automatic stay imposed by Sections 362 and
1301 of the Bankruptcy Code to enable the Movant to enforce its rights under its
Note and Deed of Trust.

13. The subject property is not necessary for an effective reorganization.

MARK MEYER

DC BAR 475552
MD BAR 15070
VA BAR 74290

ROSENBERG &

ASSOCIATES, LLC

7910 WOODMONT AVENUE

SUITE 750

BETHESDA, MARYLAND 20814

(301) 907-8000

FILE NUMBER: 39621

Case 12-28809 Doc 67 Filed 02/20/13 Page 3 of 4

WHEREFORE, the Movant, Central Mortgage Company its successors
and/or assigns, respectfully requests that this Honorable Court:

1. Enter an order terminating the automatic stay imposed by Sections 362
and 1301 of the Bankruptcy Code to enable it to proceed with a foreclosure sale of
the real property and improvements located at 18933 Treebranch Terrace,
Germantown, MD 20874; and

2. Grant such other and further relief as may be just and necessary.

___________________________________
/s/ Mark D. Meyer, Esq.
Mark D. Meyer, Esq.
Rosenberg & Associates, LLC
7910 Woodmont Avenue, Suite 750
Bethesda, Maryland 20814
(301) 907-8000

MARK MEYER

DC BAR 475552
MD BAR 15070
VA BAR 74290

ROSENBERG &

ASSOCIATES, LLC

7910 WOODMONT AVENUE

SUITE 750

BETHESDA, MARYLAND 20814

(301) 907-8000

FILE NUMBER: 39621

Case 12-28809 Doc 67 Filed 02/20/13 Page 4 of 4

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on February 20, 2013, a copy of the foregoing
Motion for Relief from the Automatic Stay was mailed, first class postage prepaid,
upon the following who were not served electronically:
Dianne M. Favre
18933 Treebranch Terrace
Germantown, MD 20874

Nancy Grigsby, Trustee
P.O. Box 958
Bowie, MD 20718

Monica Patricia McGinley
a/k/a Monica Steyskal
19710 Maycrest Way
Germantown, MD 20876

Teresa Cho Edwards, Esquire
Law Office of Teresa Cho Edwards
9500 Arena Drive #460-A, Largo MD
20774

___________________________________
/s/ Mark D. Meyer, Esq.
Mark D. Meyer, Esq.

MARK MEYER

DC BAR 475552
MD BAR 15070
VA BAR 74290

ROSENBERG &

ASSOCIATES, LLC

7910 WOODMONT AVENUE

SUITE 750

BETHESDA, MARYLAND 20814

(301) 907-8000

FILE NUMBER: 39621