12/05/2007 319 Notice of Filing of Proposed Order on Motion for Relief from Automatic Stay filed by Pro Plas LLC, John P. Murphy III Revocable Trust No. 1, 10315 LLC and John P. Murphy Filed by 10315 LLC, John P. Murphy III Revocable Trust No 1, John P Murphy III, Pro Plas LLC (RE: related document(s)77 Motion for Relief From Stay, filed by Creditor John P Murphy, Creditor Pro Plas LLC, Creditor John P. Murphy III Revocable Trust No 1, Creditor 10315 LLC). (Smotkin, Howard) (Entered: 12/05/2007)
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Doc 319
In Re:
Case No. 07-50935
Judge William S. Howard
Chapter 11
PRO MOLD, INC.
Debtor.
PRO PLAS LLC, JOHN P. MURPHY III REVOCABLE TRUST NO. 1, 10315 LLC AND JOHN P. MURPHY,
Movants,
v.
PRO MOLD, INC.,
Respondent.
NOTICE OF FILING OF PROPOSED ORDER ON MOTION FOR RELIEF FROM AUTOMATIC STAY FILED BY PRO PLAS LLC, JOHN P. MURPHY III REVOCABLE TRUST NO. 1, 10315 LLC AND JOHN P. MURPHY
Pro Plas LLC, a Missouri limited liability company; John P. Murphy III Revocable Trust No. 1; 10315 LLC, a Missouri limited liability company; and John P. Murphy (“the Murphy Entities”) file this their 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. #77). The Court ordered Howard Smotkin, attorney for the Murphy Entities, 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 the Murphy Entities submit their 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 the Murphy Entities
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.
Pro Mold, Inc.
Attorney for Debtor
Office of the U.S. Trustee
CWY Credit
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
Missouri Department of Revenue
Amended Master Service List No. 1
/s/ Howard S. Smotkin Howard S. Smotkin |
