Motion to Withdraw as Attorney Filed by Valentin T Narvaez as Ms.

Narvaez has resigned from Consumer Law Group; Consumer

Law Group will continue to represent the debtors

Three prior motions to modify plan, last one modified to defer

default on February 2, 2018. One plan modification was to retain

partial refund for the 2015 tax year.

2017 Federal tax refund totaled $2,394.00. IL refund totaled

$4,594.00. Neither was received.

for rental property at 7805 Douglas St, Morris, for $130,000 which

will result in a short sale if mortgage holder, Nationstar, approves.

Confirmation continued to 7/20.

TMD. 2 month default. Amend schedule J to remove DSO.

Modified plan for 3.1 for arrears POC, 3.3 for interest, 5.1 for third

box. Not feasible with arrears and amended IRS proof of claim.

FINAL date.

TMD. Cab lease shows corporation as owner of cab/medallion, not

debtor.

Need 2017 tax returns with business schedules to support

schedule I. Pay advices shows gross income is $3,000.00 greater

than scheduled on the B22C-1 and schedule I. Both substantially

understate D and NFS income and medallion income understated

by $150/month. Also, must document medallion related expenses.

Rental property is scheduled to break even over life of plan at

current FMV, if value of rental is determined to be higher then it

will have negative cash flow.

Modified plan 2.1 3.1, 3.2, 8.1. Resolve objections.

Adversary case 18-00147. (62 (Dischargeability - 523(a)(2), false

pretenses, false representation, actual fraud)): Complaint by

Discover Bank against Robert McMahon.

Document rental income. Debtor owns five properties. Lives in

one, rental income from two, cramming down mortgages on both,

R/E taxes for both are direct on J. Arrears objection on residence

$25K v $19K. Need CMA on residence [schedule A $31.5K /

Debtor $60K Zillow $113K]. Plan provides for surrender of two

uninhabitable properties to Cook and Will County, also attempting

to sell both. Value of 155th St property is understated on Schedule

I, crammed down in 3.2, see also POC #13. Ingraham Ave

property is also crammed down in 3.2 but no POC. Document

rent income from both rental properties. Amend I for correct rental

income. Debtor needs to show positive CF on both rental

properties. Need 2017 taxes, not filed as of 5/16/18.

Resolve Hoyne Savings Bank objection.

Amend schedule J for mortgage escrow. Modified plan to meet

CMI pot; 3.1 1st mortgage arrears $45,290.66, 2nd needs to come

back, car is direct, but arrears on proof of claim, 5.1 for third box,

7.1 for second box. Resolve objections by Wilmington Savings and

U.S. Bank. B22C-2 line #16 should be $2,024.00.

TMD. 2 month default. Amend schedule F for credit cards, debtor

is refusing to amend for disputed debts. Modified plan 2.2, 2.3,

5.1, 7.1 to check boxes, 2.4 to add PI suit language. Bar date is

May 7th.

Amend B22C-1 2A income is substantially understated and

amended schedule I understates net income and overstates

insurance deduction. Will impact the DMI/disposable income.

Modifiy plan accordingly. Per pay advices and tax returns, D

income much greater.

Amend SOFA #18. Modified plan 2.3 and to resolve Ally objection.

Need future tax returns. Equity issue because of exemption to

exemption.

Objection to Claim of FDA set for 7/13.

Debtor is now married, amend for new name - Johnson and

amend I and J for husband income and expenses including child

support and alimony. Amended schedule A for real estate value at

$111,000.00. Modified plan 2.2, 2.3, 5.1, 7.1 to check boxes, to

pay $14K to GUC due to equity, 3.1 to provide for mortgage, 3.3

to pay vehicle loan, delete from J if trustee disburses as expected.

Delete $254 "Misc" from schedule J #21. Debtor is about to have

a baby.

Amend schedule E for correct DSO address. Modified plan 3.1 for

all arrears, 3.5 for correct creditor name; need to fund $12,631.18

to IRS per POC. DSO arrears are being deducted from paycheck.