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To: scion who wrote (11696)	11/15/2007 8:43:49 AM
From: scion	Respond to of 12518

11/14/2007 305 Response Filed by Pro Plas LLC (RE: related document(s)304 Motion to Extend Time, filed by Creditor Committee Official Committee of Unsecured Creditors). (Smotkin, Howard) (Entered: 11/14/2007) ---------------------------- Doc 305 In Re: PLASTICON INTERNATIONAL, INC., Debtor. Case No. 07-50934 Judge William S. Howard Chapter 11 OBJECTION OF CREDITOR PRO PLAS, LLC TO JOINT MOTION OF DEBTOR AND CHAPTER 11 TRUSTEE TO EXTEND TIME FOR RESPONSE TO MOTION FOR RELIEF FROM AUTOMATIC STAY, AND TO RESCHEDULE HEARING Creditor Pro Plas, LLC (“Pro Plas”), by and through its attorneys, objects to the Joint Motion of Debtor and Chapter 11 Trustee to Extend Time for Response to Motion for Relief from Automatic Stay, and to Reschedule Hearing (“Motion”). In support of this objection, Pro Plas states as follows: 1. Pro Plas adopts and incorporates by reference the Objection Of Creditors The Murphy Entities To Motion Of Chapter 11 Trustee To Continue Hearing On: I. Motion For Relief From Stay And Related Deadlines; II. Motion For Immediate Surrender Of Nonresidential Real Property; And III. Motion To Convert, filed in the matter of In Re: Pro Mold, Inc., USBCEDKY Case No. 07-50935. 2. The Chapter 11 Trustee in this case, like the Chapter 11 Trustee in Pro Mold, has had an ample opportunity to retain counsel and chose instead to delay such employment. 3. While it is unlikely that the Murphy Entities will exercise their right to foreclose on the Pro Mold stock held by Plasticon, the Murphy Entities object to the Motion to the extent it seeks to delay any action that the Murphy Entities may seek to take with respect to the operating assets of Pro Mold. WHEREFORE, the Murphy Entities respectfully request that: (i) the Chapter 11 Trustee's Motion be overruled; (ii) the Motion for Relief be heard on November 19, 2007; and (iii) this Court award the Murphy Entities such other and further relief as this Court deems just and proper. STONE, LEYTON & GERSHMAN A Professional Corporation By: /s/ Howard S. Smotkin E. Rebecca Case, EDMO #2800 Howard S. Smotkin, EDMO #4407 7733 Forsyth Boulevard, Suite 500 St. Louis, Missouri 63105 (314) 721-7011 (314) 721-8660 Facsimile erc@stoneleyton.com hss@stoneleyton.com Attorneys for Pro Plas, LLC GREENEBAUM DOLL & MCDONALD PLCC John W. Ames Gregory R. Schaaf 300 West Vine Street, Suite 1100 Lexington, Kentucky 40507 (859) 288-4629 (859) 367-3877 Facsimile grs@gdm.com Local Counsel for Pro Plas, LLC CERTIFICATE OF SERVICE This is to certify that a true and correct copy of the foregoing Objection of Pro Plas, LLC to the Joint Motion of Debtor and Chapter 11 Trustee to Extend Time for Response to Motion for Relief from Automatic Stay, and to Reschedule Hearing has been served electronically in the method established under CM/ECF Administrative Procedures Manual and the Local Court Standing Order dated July 25, 2002 via electronic and/or first class, postage prepaid U.S. mail on this 14th day of November 2007. /s/ Howard S. Smotkin Howard S. Smotkin