Neither the Bankruptcy Code nor the Federal Rules of Bankruptcy Procedure allocates the burden of proof as to the value of secured claims under Code §506(a). Concluding that a burden-shifting approach was the most appropriate, the Third Circuit Court of Appeals explained that the initial burden should be on the party challenging a secured claim’s value, because Code §502(a) and Bankruptcy Rule 3001(f) granted prima facie effect to the validity and amount of a properly-filed claim. It was only fair, then, that the party seeking to negate the presumptively valid amount of a secured claim—and thereby affect the rights of a creditor—bear the initial burden. If the movant establishes with sufficient evidence that the proof of claim overvalues a creditor’s secured claim because the collateral is of insufficient value, the burden shifts. The creditor thereafter bears the ultimate burden of persuasion to demonstrate by a preponderance of the evidence in both the extent of its lien and the value of the collateral securing its claim. In re Heritage Highgate, Inc., 2012 WL 1664174.