Case 11-45314

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UNITED STATES BANKRUPTCY COURT DISTRICT OF MINNESOTA

In Re: Benjamin Jones-Norman Debtor.

Case No. BKY 11-45314

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

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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 102 Plymouth, 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 the best of my knowledge, information and belief. Executed: 5-18-2012 /e/David C. Olson

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United States Bankruptcy Court District of Minnesota IN RE:

Jones-Norman, Benjamin L
Debtor(s)

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Case No. 11-45314 Chapter 13 CERTIFICATE OF MAILING

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

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was(were) mailed to all persons in interest at the addresses set forth in the exhibit which is attached hereto, by first class mail, May postage prepaid, on this 18th day of , 2012 .

/s/ David C. Olson David C. Olson 169055 Lanners and Olson, P.A. 12805 Hwy. 55 Suite 102 Plymouth, MN 55441 (763) 550-9892 Fax: (763) 550-9630 olsond@landolaw.com

Case 11-45314
Acura Financial Services 2170 Point Blvd, Ste 100 Elgin, IL 60123

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American Express P O Box 0001 Los Angeles, CA 90096

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Asni P O Box 3517 1310 MLK Drive Bloomington, IL 61702-3517

Capital One Bank Bankruptcy Department P O Box 85520 Richmond, VA 23285

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

Citi P O Box 6241 Sioux Falls, SD 57117

Direct TV Qwest Communication P O Box 29080 Phoenix, AZ 85038-9080

TCF Home Equity Line Of Credit

US Department Of Education P O Box 5609 Greenville, TX 75403

Wells Fargo

Wells Fargo Home Mortgage P O Box 10388 Des Moines, IA 50306

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