12/05/2007 328 Notice of Filing of Proposed Order on Motion for Relief from Automatic Stay Filed by Pro Plas LLC Filed by Pro Plas LLC (RE: related document(s)83 Motion for Relief From Stay filed by Creditor Pro Plas LLC). (Smotkin, Howard) (Entered: 12/05/2007
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Doc 328
In Re:
Case No. 07-50934
Judge William S. Howard
Chapter 11
PLASTICON INTERNATIONAL, INC.
Debtor.
PRO PLAS LLC
Movant,
v.
PLASTICON INTERNATIONAL, INC.,
Respondent.
NOTICE OF FILING OF PROPOSED ORDER ON MOTION FOR RELIEF FROM AUTOMATIC STAY FILED BY PRO PLAS LLC
Pro Plas LLC, a Missouri limited liability company (“Pro Plas”) file this its Notice of Filing of Proposed Order on Motion for Relief from Automatic Stay in the above-styled and numbered case.
On November 19, 2007 the Court heard the Motion for Relief from Automatic Stay (D.E. #83). The Court ordered Howard Smotkin, attorney for Pro Plas, to prepare and circulate a proposed Order prior to filing the proposed Order with the Clerk of the Court.
The proposed Order was prepared and circulated from November 21, 2007 through December 4, 2007 with various revisions being made. Unfortunately, the parties were unable to reach an agreement on certain issues.
Consequently, counsel for Pro Plas submits its version in the form of the Order that is being filed contemporaneously with this Notice.
/s/ Howard S. Smotkin
Howard S. Smotkin
STONE, LEYTON & GERSHMAN
A Professional Corporation
7733 Forsyth Boulevard, Suite 500
St. Louis, Missouri 63105
(314) 721-7011
(314) 721-8660 Facsimile
hss@stoneleyton.com
Attorneys for Pro Plas LLC
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing document was mailed and/or electronically served on this 5th day of December 2007 to the parties listed below.
Plasticon International, Inc.
Attorney for Debtor
Office of the U.S. Trustee
Eric Assouline
Gregory R. Schaaf Attorney for Official Unsecured Creditors’ Committee in Plasticon International, Inc. Kenneth C. Henry Attorney for Pro Mold Chapter 11 Trustee
Steven Palmer
Attorney for Plasticon Chapter 11 Trustee Master Service List No. 1
/s/ Howard S. Smotkin Howard S. Smotkin |
