09/06/2007 191 Notice of Appearance and Request for Notice by Leslie Dean Filed by on behalf of Eagle View One, LLC. (Dean, Leslie) (Entered: 09/06/2007)
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Doc 191
UNITED STATES BANKRUPTCY COURT
EASTERN DISTRICT OF KENTUCKY
LEXINGTON DIVISION
IN RE:
PLASTICON INTERNATIONAL
Case No. 07-50934
Debtor Chapter 11
NOTICE OF APPEARANCE AND REQUEST FOR SERVICE OF PAPERS
Please take note that the undersigned hereby appears as counsel for EAGLE VIEW ONE, LLC, A KENTUCKY LIMITED LIABILITY COMPANY, an interested party in this case and by virtue of that certain lease with said debtor involving contractual rights and obligations related thereto, at which time the debtor is not current on its commercial lease payments to Eagle View One, LLC, and which leave for eviction proceedings to commence is being sought, and pursuant to Rules 2002 and 9007 of the Federal Rules of Bankruptcy Procedure (the "Bankruptcy Rules"), the local Bankruptcy Rules for the Eastern District of Kentucky and Section 1109(b) of Title 11 of the United States Code, requests that all notices given or required to be given, and all papers and pleadings filed or served or required to be served in this case, be given and served upon:
Leslie Dean, Esq.
LESLIE DEAN, ATTORNEY AT LAW, PSC
One Eagle View Plaza
3288 Eagle View Lane
Suite 300,
Lexington, Kentucky 40509
T: (859) 296-4575
F: (859) 296-4577
ldean@LeslieDean.com
Further, take notice that Eagle View One, LLC, a Kentucky Limited Liability Company, intends that neither this Notice of Appearance nor any later appearance, pleading, claim, or suit shall waive EAGLE VIEW ONE, LLC's right to have final orders in non-core matters entered only after de novo review by a District Judge; (2) Creditor's right to trial by jury in any proceeding so triable in this case or any case, controversy, or proceeding related to this case; (3) EAGLE VIEW ONE, LLC's right to have the District Court withdraw the reference in any matter subject to mandatory or discretionary withdrawal; or (4) any other rights, claims, actions, defenses, setoffs, or recoupments to which EAGLE VIEW ONE, LLC is or may be entitled to under agreement, in law, in equity, or otherwise, all of which rights, claims, actions, defenses, setoffs, and recoupments EAGLE VIEW ONE, LLC expressly reserves.
Submitted this the 6th day of September, 2007.
/s/ Leslie Dean_________________________
LESLIE DEAN, ATTORNEY AT LAW, PSC
One Eagle View Plaza
3288 Eagle View Lane, Suite 300
Lexington, Kentucky 40509
Telephone: (859) 296-4575
Facsimile: (859) 296-4577
Email: ldean@LeslieDean.com
ATTORNEY FOR EAGLE VIEW ONE, LLC
CERTIFICATE OF SERVICE
The undersigned hereby certifies that a true and correct copy of the foregoing has been served on the below-listed parties by U.S. mail, postage prepaid, and all parties receiving CM/ECF pleadings on this the 6th day of September, 2007.
Plasticon International, Inc.;
Fower, Measle, & Bell, LLC; and
Wyatt, Tarrant & Combs, LLP
/s/ Leslie Dean |
