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To: scion who wrote (11885)12/18/2007 10:13:11 AM
From: scion  Respond to of 12518
 
December 6, 2007 Order (D.E. #330)

Message 24114700

December 6, 2007 Order (D.E. #330)

7. On December 6, 2007 the Court signed and the Clerk entered the Order on Motion for Relief from Automatic Stay filed by Pro Plas. (“Order”)(D.E. #330) and the Order is incorporated herein by reference.

8. Pro Plas requests immediate relief from the automatic stay of 11 U.S.C. Section 362 pursuant to paragraph A of the Order (D.E. #330) concurrent with the granting of relief from the automatic stay in Debtor Pro Mold, Inc.’s case (USBC-EDKY Case No. 07-50935).

WHEREFORE, Pro Plas requests:

A. that the Court order the following:

1. Pro Plas be granted immediate relief from the automatic stay to proceed with its state court remedies and foreclose on its respective security interests in Debtor Plasticon’s personal property (“PLNI Collateral”).

B. such other and further relief as the Court deems just.