HTML Document View

Full title: Response (Filed By Reynol Saldivar Welding Services, LLC ).(Related document(s):1352 Objection to Claim) (Cain, David) (Entered: 04/21/2021)

Document posted on Apr 20, 2021 in the bankruptcy, 2 pages and 0 tables.

Bankrupt11 Summary (Automatically Generated)

Service, LLC (hereafter “Saldivar”), a Creditor in this case, and files this, Response to the Liquidation Trustee's Second Omnibus Claims Objection (Late-Filed Claims), Movant, and grounds therefore would show as follows: I. Saldivar admits the allegations in Paragraphs 2, 3, 4, 5, 6, 7, 8, 9 of Movant's Motion.Saldivar admits the allegations in Paragraphs 14, except the allegation that each claimant was provided timely notice of the Bar Date Order and had adequate notice of the Bar Date.The allegations in paragraphs 1, 12, 13, 15, 16, 17, 18 and 21 of Movant's Motion do nor contain factual allegations.Saldivar's did not receive the Bar Date Order referred to in Movant’s Motion or any other notice that the previously set Bar Date had been change.CERTIFICATE OF SERVICE I hereby certify that on April 21, 2021 a true and correct copy of the above and foregoing was served upon the following parties via electronic means as listed on the Court's ECF Noticing System or by regular first class mail: Travis A Roberts 2000 McKinney Ave, Suite 1700

List of Tables

Document Contents

UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF TEXAS HOUSTON DIVISION In Re: BJ Services, LLC, et al § Case No. 20-33627 § § DEBTOR § Chapter 13 RESPONSE TO LIQUIDATION TRUSTEE'S SECOND OMNIBUS CLAIMS OBJECTION (LATE-FILED CLAIMS) TO THE HONORABLE JUDGE OF SAID COURT: Comes now Reynol Saldivar Welding Service, LLC (hereafter “Saldivar”), a Creditor in this case, and files this, Response to the Liquidation Trustee's Second Omnibus Claims Objection (Late-Filed Claims), Movant, and grounds therefore would show as follows: I. Saldivar admits the allegations in Paragraphs 2, 3, 4, 5, 6, 7, 8, 9 of Movant's Motion. II. Saldivar admits the allegations in Paragraphs 14, except the allegation that each claimant was provided timely notice of the Bar Date Order and had adequate notice of the Bar Date. III Saldivar denies the allegations in paragraphs 10 of Movant's Motion. VI. Saldivar lacks sufficient information to admit or deny the allegations in paragraphs 11, 19 and 20 of Movant's Motion. V. The allegations in paragraphs 1, 12, 13, 15, 16, 17, 18 and 21 of Movant's Motion do nor contain factual allegations. VI. When this case was filed Saldivar received the Official Form 309F1, Notice of Chapter 11 Bankruptcy Case. This Notice set the deadline for filing proofs of claim as December 9, 2020. Saldivar justifiably relied upon this Notice in determining when to file its claim in this

1

case. Saldivar's did not receive the Bar Date Order referred to in Movant’s Motion or any other notice that the previously set Bar Date had been change. PRAYER WHEREFORE, PREMISES CONSIDERED, Debtor prays that Liquidation Trustee's Second Omnibus Claims Objection be denied as to Reynol Saldivar Welding Service, LLC. Respectfully submitted, Law Office of David T. Cain 8626 Tesoro., Ste. 811 San Antonio, Texas 78217 (210) 308-0388; (FAX) 341-8432 /s/ David T. Cain _________________________________ David T. Cain State Bar No. 03598800 CERTIFICATE OF SERVICE I hereby certify that on April 21, 2021 a true and correct copy of the above and foregoing was served upon the following parties via electronic means as listed on the Court's ECF Noticing System or by regular first class mail: Travis A Roberts 2000 McKinney Ave, Suite 1700 Dallas, Texas 76201 Attorney for Norman N. Kinel Liquidating Trustee of BJS Liquidation Trust /s/ David T. Cain _________________________________ David T. Cain

2