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To: scion who wrote (11897)	12/20/2007 11:31:04 AM
From: scion	Respond to of 12518

12/20/2007 336 Objection Filed by Stephen Palmer (RE: related document(s)334 Motion for Miscellaneous Relief, filed by Creditor Pro Plas LLC). (Attachments: # 1 Continuation of Main Document Trustee Henry objection in Pro Mold bankruptcy) (Barnes, Stephen) (Entered: 12/20/2007) -------------------- Doc 336 In Re: Case No.: 07-50934 PLASTICON INTERNATIONAL, INC. DEBTOR TRUSTEE PALMER’S OBJECTION TO MOTION FOR RELIEF OF PRO PLAS, LLC Comes now the Trustee, Stephen Palmer (the “Trustee Palmer”), solely in his capacity as the Trustee for the Chapter 11 Bankruptcy Estate (the “Estate”) of Plasticon International, Inc. (the “Debtor”), and hereby respectfully submits his Objection to the Motion for Relief from Stay (Docket No. 334) (the “Pro Plas Motion”) filed by Creditor Pro Plas, LLC (“Pro Plas”). For his objection, the Trustee states as follows: 1. This Court should deny the Motion because several necessary determinations have not been made in connection with Pro Plas’ claim and the related collateral. Specifically, the following items are unknown: (i) the dollar amount of the claims based on the three Murphy notes, (ii) the identification of collateral which allegedly secures the Murphy notes, and (iii) the amount of reasonable attorneys’ fees allegedly due under the Murphy notes. 2. The Trustee respectfully requests that this Court make the three determinations listed above. Until these three determinations are made, Pro Plas will not have met its burden to show that it is entitled to relief from stay. 3. Additionally, the Trustee incorporates by reference and adopts the December 19, 2007 Response filed by Trustee Kenneth C. Henry (Trustee for the Chapter 11 Bankruptcy Estate of Pro Mold, Inc.) in the Pro Mold Inc. bankruptcy proceedings (E.D. Ky. Case No. 07-50935). A copy of Trustee Henry’s response is electronically attached hereto. WHEREFORE, for the reasons set forth above, Trustee Palmer requests this Court to enter an Order: 1. OVERRULING the Pro Plas Motion, and 2. Granting such further relief as is just proper, necessary, or appropriate. Notice Please take notice that a telephonic hearing shall be heard on this matter on Thursday, December 19, 2007 at the hour of 10:00 am EST before the Honorable Bankruptcy Judge William Howard of the U.S. Bankruptcy Court for the Eastern District of Kentucky. Interested parties should telephone the chambers of Judge Howard at (859) 233-2465. Dated this the 21st day of December, 2007. Respectfully Submitted, /s/ Stephen Barnes Walther, Roark & Gay, PLC 163 E. Main Street, Suite 200 P.O. Box 1598 Lexington, KY 40588-1598 (tel) (859) 225-4714 (fax) (859) 225-7983 sbarnes@wrgfirm.com ATTORNEY FOR THE TRUSTEE CERTIFICATE OF SERVICE This is to certify that a copy of the foregoing was served upon the individuals and entities entitled to receive electronic notice on this the 21st day of December, 2007.** /s/ Stephen Barnes ATTORNEY FOR THE TRUSTEE