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Full title: Objection to Other Document (RE: related document(s)1833 Motion (Other) filed by Debtor Bestwall LLC) filed by Thomas W. Waldrep Jr. on behalf of Illinois Individuals. (Waldrep, Thomas) (Entered: 06/29/2021)

Document posted on Jun 28, 2021 in the bankruptcy, 9 pages and 0 tables.

Bankrupt11 Summary (Automatically Generated)

James David Butler on behalf of Claimants of Certain Law Firms Listed On Appendix A to the Complaint Katharine C. Byrne on behalf of Cooney & Conway Garland S. Cassada on behalf of the Debtor John D. Cooney on behalf of Cooney & Conway and Claimants of Cooney and Conway Listed On Appendix A To The Complaint Robert A. Cox, Jr. on behalf of The Official Committee of Asbestos Claimants of Bestwall, LLC Kevin R. Crandall on behalf of the Debtor Heather W. Culp on behalf of Claimants of Bailey Peavy Bailey Cowen Heckaman PLLC Listed On Appendix A; Claimants of Brayton Purcell, LLP Listed On The Appendix A To The Complaint; Claimants of Buck Law Firm Listed On Appendix A To The Complaint; Claimants of Certain Law Firms Listed On Appendix A to the Complaint; Claimants of Cohen Placitella & Roth P.C. Listed On Appendix A To The Complaint; Claimants of Cooney and Conway Listed On Appendix A To The Complaint; Claimants of Flint Law Firm, LLC Listed On Appendix A To The Complaint; Claimants of Gori Julian & Associates, P.C. Listed On Appendix A To The Complaint; Claimants of Kazan, McClain, Satterley & Greenwood Listed On Appendix A To The Complaint; Claimants of Kazan, McClain, Satterley & Greenwood Listed On Appendix A To The Complaint; Claimants of Keller Fishback & Jackson, LLP Listed On Appendix A To The Complaint; Claimants of Kelley & Ferraro LLP Listed On Appendix A to the Complaint; Claimants of Law Offices of Peter G. Angelos, P.C. Listed On Appendix A To The Complaint; Claimants of Levy Konigsberg, LLP Listed On Appendix A To The Complaint; Claimants of Maune, Raichle, Hartley, French & Mudd, LLC Listed On The Appendix A To The Complaint; Claimants of Michael B. Serling, P.C. Listed On Appendix A to the Complaint; Claimants of Nass Cancelliere Listed On Appendix A To The Complaint; Claimants of Nemeroff Law Firm, PC Listed On Appendix A To The Complaint; Claimants of O'Brien Law Firm, P.C.Listed On Appendix A To The Complaint; Claimants of Rebecca S. Vinocur, P.A. Listed On Appendix A To The Complaint; Claimants of SWMW Law, LLC Listed On Appendix A To The Complaint; Claimants of Savinis Kane & Galluci, LLC and Prim Law Firm, PLLC Listed On Appendix A To The Complaint; Claimants of Shepard Law, P.C. Listed On Appendix A To The Complaint; Claimants of The Deaton Law Firm Listed On Appendix A To The Complaint; Claimants of The Ferraro Law Firm, P.A. Listed On Appendix A To The Complaint; Claimants of The Lanier Law Firm, PC Listed On Appendix A To The Complaint; Claimants of Thornton Law Firm, LLP Listed On Appendix A To The Complaint; Claimants of Waters & Kraus, LLP Listed On Appendix A To The Complaint; Claimants of Weitz & Luxenberg, P.C. Listed On Appendix A To The Complaint; and Claimants of Wilentz, Goldman & Spitzer, P.A.To The Complaint Kenneth J. Fryncko on behalf of Claimants of Savinis Kane & Galluci, LLC and Prim Law Firm, PLLC Listed On Appendix A To The Complaint Mark P. Goodman on behalf of Georgia-Pacific

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IN THE UNITED STATES BANKRUPTCY COURT FOR THE WESTERN DISTRICT OF NORTH CAROLINA CHARLOTTE DIVISION In re: Chapter 11 BESTWALL LLC, Case No. 17-31795 (LTB) Debtor. ___________________________________ OBJECTION TO DEBTOR’S EMERGENCY MOTION TO ENFORCE PIQ ORDER AND AUTOMATIC STAY NOW COME the Illinois Individuals,1 by and through the undersigned counsel, and hereby submit this objection (the “Objection”) to the Debtor’s Emergency Motion to Enforce PIQ Order and Automatic Stay (the “Emergency PIQ Motion”) [ECF No. 1833]. In support of this Objection, the Illinois Individuals respectfully state as follows: 1. The Illinois Individuals only recently, and after the filing of the Illinois Lawsuit2, engaged the undersigned counsel to represent them in the contested matter initiated by the Emergency PIQ Motion. As an initial matter, the Illinois Individuals request that the Court direct pursuant to Fed. R. Bankr. P. 9014(c) that Fed. R. Bankr. P. 7012 apply to this contested matter. Should the Court so direct, the Illinois Individuals assert the following defenses pursuant to Fed. R. Civ. P. 12(b): a. Lack of subject matter jurisdiction; b. Lack of personal jurisdiction; 1 The Illinois Individuals are as follows: Patricia Blair, as personal representative (“PR”) for the Estate of Lee Blair; Violet Butler, as PR for the Estate of Ralph Butler; Betty Jean Camilleri, as PR for the Estate of Terrence Camilleri; Cheryl D. Wooter, as PR for the Estate of William Cutler; Kimberly Plant, as special administrator of the Estate of Sheryl Evans; Maria Fons, as PR for the Estate of Miguel Fons; Christopher Nelson, as PR for the Estate of Roger Nelson; and Melissa Taylor, as PR for the Estate of Donald Taylor. 2 Capitalized terms not otherwise defined herein shall have the meanings given in the Emergency PIQ Motion.

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c. Insufficient process; and d. Insufficient service of process. 2. The Illinois Individuals further assert the following: a. That the timeline requested by the Debtor in the Emergency PIQ Motion does not afford them reasonable notice and an opportunity for hearing pursuant to Fed. R. Bankr. P. 9014(a); b. That the Emergency PIQ Motion was not properly served on the Illinois Individuals pursuant to Fed. R. Bankr. P. 7004, incorporated into this contested matter by Fed. R. Bankr. 9014(b); and c. That the Emergency PIQ Motion, as a Request for Relief, was not properly served on the Illinois Individuals pursuant to the Order Establishing Certain Notice, Case Management and Administrative Procedures (Dkt. No. 65). WHEREFORE, the Illinois Individuals respectfully request the Court: A. Deny the Emergency PIQ Motion; B. In the alternative, continue the hearing currently set for June 30, 2021; C. In the alternative: a. Treat the hearing currently set for June 30, 2021 as a preliminary hearing; b. Set a reasonable deadline for the Illinois Individuals to substantively respond to the Emergency PIQ Motion; and c. Enter a scheduling order providing for, among other things a reasonable period for discovery pursuant to Fed. R. Bankr. P. 7026, 7028-7037, as incorporated into this contested matter by Fed. R. Bankr. P. 9014(c); a deadline for dispositive motions; and a final evidentiary hearing; and

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D. Enter such other and further orders and the Court deems necessary and proper. Respectfully submitted, this the 29th day of June, 2021. WALDREP WALL BABCOCK & BAILEY PLLC /s/ Thomas W. Waldrep, Jr. Thomas W. Waldrep, Jr. (NC Bar No. 11135) James C. Lanik (NC Bar No. 30454) Jennifer B. Lyday (NC Bar No. 39871) John R. Van Swearingen (NC Bar No. 53646) 1076 West Fourth Street Winston-Salem, NC 27101 Telephone: 336-717-1280 Telefax: 336-717-1340 Email: notice@waldrepwall.com Counsel for the Illinois Individuals

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CERTIFICATE OF SERVICE The undersigned hereby certifies that the foregoing OBJECTION TO DEBTOR’S EMERGENCY MOTION TO ENFORCE PIQ ORDER AND AUTOMATIC STAY was filed in accordance with the local rules and served upon all parties registered for electronic service and entitled to receive notice thereof through the CM/ECF system. This, the 29th day of June, 2021. WALDREP WALL BABCOCK & BAILEY PLLC /s/ Thomas W. Waldrep, Jr. Thomas W. Waldrep, Jr. (NC Bar No. 11135) James C. Lanik (NC Bar No. 30454) Jennifer B. Lyday (NC Bar No. 39871) John R. Van Swearingen (NC Bar No. 53646) 1076 West Fourth Street Winston-Salem, NC 27101 Telephone: 336-717-1280 Telefax: 336-717-1340 Email: notice@waldrepwall.com Counsel for the Illinois Individuals VIA CM/ECF Eric B. Abramson on behalf of Claimants of Michael B. Serling, P.C. Listed On Appendix A to the Complaint Darren Azman on behalf of Honeywell International Inc. Jason Kyle Beale on behalf of Claimants of Bailey Peavy Bailey Cowen Heckaman PLLC Listed On Appendix A To The Complaint Gill Beck on behalf of the United States of America Thomas W. Bevan on behalf of Claimants of Bevan and Associates LPA, Inc. Listed On Appendix A To The Complaint Jennifer Black on behalf of Claimants of Nemeroff Law Firm, PC Listed On Appendix A To The Complaint Demi Lorant Bostian on behalf of the Debtor Charles W. Branham, III on behalf of Dean Omar & Branham, LLP

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Robert C. Buck on behalf of Claimants of Buck Law Firm Listed On Appendix A To The Complaint James David Butler on behalf of Claimants of Certain Law Firms Listed On Appendix A to the Complaint Katharine C. Byrne on behalf of Cooney & Conway Garland S. Cassada on behalf of the Debtor John D. Cooney on behalf of Cooney & Conway and Claimants of Cooney and Conway Listed On Appendix A To The Complaint Robert A. Cox, Jr. on behalf of The Official Committee of Asbestos Claimants of Bestwall, LLC Kevin R. Crandall on behalf of the Debtor Heather W. Culp on behalf of Claimants of Bailey Peavy Bailey Cowen Heckaman PLLC Listed On Appendix A To The Complaint; Claimants of Bevan and Associates LPA, Inc. Listed On Appendix A To The Complaint; Claimants of Brayton Purcell, LLP Listed On The Appendix A To The Complaint; Claimants of Buck Law Firm Listed On Appendix A To The Complaint; Claimants of Certain Law Firms Listed On Appendix A to the Complaint; Claimants of Cohen Placitella & Roth P.C. Listed On Appendix A To The Complaint; Claimants of Cooney and Conway Listed On Appendix A To The Complaint; Claimants of Flint Law Firm, LLC Listed On Appendix A To The Complaint; Claimants of Gori Julian & Associates, P.C. Listed On Appendix A To The Complaint; Claimants of Kazan, McClain, Satterley & Greenwood Listed On Appendix A To The Complaint; Claimants of Kazan, McClain, Satterley & Greenwood Listed On Appendix A To The Complaint; Claimants of Keller Fishback & Jackson, LLP Listed On Appendix A To The Complaint; Claimants of Kelley & Ferraro LLP Listed On Appendix A to the Complaint; Claimants of Law Offices of Peter G. Angelos, P.C. Listed On Appendix A To The Complaint; Claimants of Levy Konigsberg, LLP Listed On Appendix A To The Complaint; Claimants of Maune, Raichle, Hartley, French & Mudd, LLC Listed On The Appendix A To The Complaint; Claimants of Michael B. Serling, P.C. Listed On Appendix A to the Complaint; Claimants of Nass Cancelliere Listed On Appendix A To The Complaint; Claimants of Nemeroff Law Firm, PC Listed On Appendix A To The Complaint; Claimants of O'Brien Law Firm, P.C. Listed On Appendix A To The Complaint; Claimants of Rebecca S. Vinocur, P.A. Listed On Appendix A To The Complaint; Claimants of SWMW Law, LLC Listed On Appendix A To The Complaint; Claimants of Savinis Kane & Galluci, LLC and Prim Law Firm, PLLC Listed On Appendix A To The Complaint; Claimants of Shepard Law, P.C. Listed On Appendix A To The Complaint; Claimants of The Deaton Law Firm Listed On Appendix A To The Complaint; Claimants of The Ferraro Law Firm, P.A. Listed On Appendix A To The Complaint; Claimants of The Lanier Law Firm, PC Listed On Appendix A To The Complaint; Claimants of Thornton Law Firm, LLP Listed On Appendix A To The Complaint; Claimants of Waters & Kraus, LLP Listed On Appendix A To The Complaint; Claimants of Weitz & Luxenberg, P.C. Listed On Appendix A To The Complaint; and Claimants of Wilentz, Goldman & Spitzer, P.A. Listed On Appendix A To The Complaint

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Kenneth Brian Dantinne on behalf of The Official Committee of Asbestos Claimants of Bestwall, LLC Timothy A. Davidson, II on behalf of Liquidity Solutions, Inc. Harry Lee Davis, Jr. on behalf of Honeywell International Inc. John R. Deaton on behalf of Claimants of The Deaton Law Firm Listed On Appendix A To The Complaint Jeffrey Brian Ellman on behalf of the Debtor Brad B. Erens on behalf of the Debtor B. Chad Ewing on behalf of Manville Personal Injury Settlement Trust and Delaware Claims Processing Facility James L. Ferraro, Sr. on behalf of Claimants of The Ferraro Law Firm, P.A. Listed On Appendix A To The Complaint Kenneth J. Fryncko on behalf of Claimants of Savinis Kane & Galluci, LLC and Prim Law Firm, PLLC Listed On Appendix A To The Complaint Mark P. Goodman on behalf of Georgia-Pacific LLC Gregory M. Gordon on behalf of the Debtor Beth Gori on behalf of Claimants of Gori Julian & Associates, P.C. Listed On Appendix A To The Complaint William Marc Graham on behalf of Dean Omar & Branham, LLP Timothy M. Haggerty on behalf of Manville Personal Injury Settlement Trust and Delaware Claims Processing Facility Barbara Harding on behalf of the Debtor Raymond Paul Harris, Jr. on behalf of the Debtor Edwin J. Harron on behalf of Sander Esserman David A. Jagolinzer on behalf of Claimants of The Ferraro Law Firm, P.A. Listed On Appendix A To The Complaint Steven Kazan on behalf of Claimants of Kazan, McClain, Satterley & Greenwood Listed On Appendix A To The Complaint

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Daniel Keller on behalf of Claimants of Keller Fishback & Jackson, LLP Listed On Appendix A To The Complaint Peter D. Kieselbach on behalf of U.S. Bank National Association, as Trustee Maura Kolb on behalf of Claimants of The Lanier Law Firm, PC Listed On Appendix A To The Complaint Jonathan C. Krisko on behalf of the Debtor William L. Kuzmin on behalf of Claimants of Cohen Placitella & Roth P.C. Listed On Appendix A To The Complaint M. Natasha Labovitz on behalf of Georgia-Pacific LLC Andrea Landry on behalf of Claimants of Thornton Law Firm, LLP Listed On Appendix A To The Complaint Bryn Gallagher Letsch on behalf of Clients of Brayton Purcell LLP Jeff A. McCurdy on behalf of Foster & Sear Chris McKean on behalf of Claimants of Maune, Raichle, Hartley, French & Mudd, LLC Listed On The Appendix A To The Complaint John R. Miller, Jr. on behalf of Georgia-Pacific LLC Edward M. Nass on behalf of Claimants of Nass Cancelliere Listed On Appendix A To The Complaint Diedre Woulfe Pacheco on behalf of Claimants of Wilentz, Goldman & Spitzer, P.A. Listed On Appendix A To The Complaint Michael s. Palmieri on behalf of Manville Personal Injury Settlement Trust and Delaware Claims Processing Facility Felton Parrish on behalf of Young Conaway Stargatt & Taylor, LLP; Sander Esserman; and Ankura Consulting Group, LLC James L. Patton, Jr. on behalf of Sander Esserman Stuart L. Pratt on behalf of the Debtor Jill M. Price on behalf of Claimants of Flint Law Firm, LLC Listed On Appendix A To The Complaint

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Natalie D. Ramsey on behalf of Simmons Hanly Conroy LLC and The Official Committee of Asbestos Claimants of Bestwall, LLC Audrey Raphael on behalf of Claimants of Levy Konigsberg, LLP Listed On Appendix A To The Complaint Ryan Reimers on behalf of U.S. Bank National Association, as Trustee Jason C. Rubinstein on behalf of Manville Personal Injury Settlement Trust and Delaware Claims Processing Facility Amanda Rush on behalf of the Debtor Cary Ira Schachter on behalf of the Debtor David M. Schilli on behalf of the Debtor Richard A. Schneider on behalf of the Debtor Michael Shepard on behalf of Claimants of Shepard Law, P.C. Listed On Appendix A To The Complaint Robert Eugene Shuttlesworth on behalf of Shrader Charles S. Siegel on behalf of Claimants of Waters & Kraus, LLP Listed On Appendix A To The Complaint Linda Wright Simpson on behalf of The Official Committee of Asbestos Claimants of Bestwall, LLC Andrew W.J. Tarr on behalf of the Debtor John F. Theil on behalf of Claimants of SWMW Law, LLC Listed On Appendix A To The Complaint Erin A. Therrian on behalf of the Debtor Glenn C. Thompson on behalf of The Official Committee of Asbestos Claimants of Bestwall, LLC Christopher J. Thoron on behalf of Claimants of O'Brien Law Firm, P.C. Listed On Appendix A To The Complaint Matthew L. Tomsic on behalf of Georgia-Pacific LLC

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Constantine Venizelos on behalf of Claimants of Kelley & Ferraro LLP Listed On Appendix A to the Complaint Rebecca S. Vinocur on behalf of Claimants of Rebecca S. Vinocur, P.A. Listed On Appendix A To The Complaint Armand J. Volta, Jr. on behalf of Claimants of Law Offices of Peter G. Angelos, P.C. Listed On Appendix A To The Complaint Jason L. Walters on behalf of Honeywell International Inc. Perry Weitz on behalf of Claimants of Weitz & Luxenberg, P.C. Listed On Appendix A To The Complaint Richard C. Worf on behalf of the Debtor Davis Lee Wright on behalf of The Official Committee of Asbestos Claimants of Bestwall, LLC Travis G. Buchanan on behalf of Sander Esserman

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