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Full title: Response opposed to (related document(s): 828 Notice of intent to abandon filed by Trustee Diane G. Reed) filed by Creditor Mitchell Warren. (Petrocchi, Mark)

Document posted on Aug 16, 2021 in the bankruptcy, 4 pages and 0 tables.

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THE LASALLE GROUP, INC. § DEBTOR § RESPONSE TO NOTICE OF INTENT TO ABANDON TO THE HONORABLE STACEY G. C. JERNIGAN, U.S. BANKRUPTCY JUDGE: NOW COMES Mitchell W. WarrenThose assets are described as: all chattel paper, accounts, notes receivable, interest receivable, contract rights, licenses and general intangibles, including all partnership interests and limited liability company interests; whether any of the foregoing is owned now or acquired later; all accessions, additions, replacements, and substitutions relating to any of the forgoing; all records of any kind relating to the foregoing; all proceeds relating to any of the foregoing including insurance, general intangibles and other account proceeds, (the “Assets”).The Trustee expressly states in paragraph (1) of the Notice that to the extent the transfer of a portion of the Assets on a pre-petition basis constitutes a fraudulent transfer claim, the Trustee seeks to abandon the right to pursue the fraudulent transfer claim under 11 U.S.C. §548. Warren references the J&M Family Management, LLC (the “J&M Response”), filed by J&M. Warren joins the position of J&M in the J&M Response with respect to the value of Assets in the motivation of Origin Bank.To the extent that the Court does authorize the abandonment of those Assets, no request has been made by Origin or the Trustee for determination of Origin’s right in those Assets and Warren objects to any determination being made with respect to perfection or other claims of interest by Origin in those Assets.

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Mark J. Petrocchi State Bar No. 15851750 GRIFFITH, JAY & MICHEL, LLP 2200 Forest Park Blvd. Fort Worth, TX 76110 Phone (817) 926-2500 Fax (817) 926-2505 mpetrocchi@lawgjm.com ATTORNEYS FOR MITCHELL W. WARREN IN THE UNITED STATES BANKRUPTCY COURT FOR THE NORTHERN DISTRICT DALLAS DIVISION IN RE: § § CASE NO. 19-31484-11 THE LASALLE GROUP, INC. § DEBTOR § RESPONSE TO NOTICE OF INTENT TO ABANDON TO THE HONORABLE STACEY G. C. JERNIGAN, U.S. BANKRUPTCY JUDGE: NOW COMES Mitchell W. Warren (“Warren”), and files this his Response to Notice of Intent to Abandon in opposition to the Notice of Intent to Abandon Certain Property of the Estate (the “Notice”, Dkt. No. 828), filed by Diane G. Reed, the Chapter 7 Trustee (“Trustee”) and in support thereof, would respectfully show the Court as follows: I. Introduction 1. The Notice indicates that Assets being abandoned “would bring no funds into the estate for the benefit of creditors”. This statement is incorrect. J&M Family Management, LLC (“J&M”) has offered and continues to be willing to purchase Assets from the estate. The Assets which the Trustee has noticed for abandonment are not of inconsequential value and are not burdensome to the estate. Response to Notice of Intent to Abandon Page 1 of 4

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II. Response to Notice 2. The Trustee filed a Notice of Intent to Abandon Certain Assets of the Estate. Those assets are described as: all chattel paper, accounts, notes receivable, interest receivable, contract rights, licenses and general intangibles, including all partnership interests and limited liability company interests; whether any of the foregoing is owned now or acquired later; all accessions, additions, replacements, and substitutions relating to any of the forgoing; all records of any kind relating to the foregoing; all proceeds relating to any of the foregoing including insurance, general intangibles and other account proceeds, (the “Assets”). 3. The Trustee’s Notice says that Origin Bank has filed a UCC Financing Statement claiming an interest in the Assets. The Trustee alleges that a statement was filed with the Secretary of State on or about January 19, 2018. The Trustee has concluded that the estate’s interest, if any, in those Assets would bring no funds to the estate for the benefit of creditors. The Trustee expressly states in paragraph (1) of the Notice that to the extent the transfer of a portion of the Assets on a pre-petition basis constitutes a fraudulent transfer claim, the Trustee seeks to abandon the right to pursue the fraudulent transfer claim under 11 U.S.C. §548. 4. J&M has previously attempted to negotiate with the Trustee concerning the potential purchase of rights and certain assets including some of the assets that are described as being abandoned by the Trustee. It is the position of Warren that those Assets have value to the estate that may result in a benefit to other creditors. Warren references the J&M Family Management, LLC (the “J&M Response”), filed by J&M. Warren joins the position of J&M in the J&M Response with respect to the value of Assets in the motivation of Origin Bank. 5. Warren opposes the Notice and request determination from this Court that the Assets described by the Trustee should not be abandoned. Response to Notice of Intent to Abandon Page 2 of 4

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6. It is the position of Warren that as long as J&M has made a material offer for some or all of the Assets that are subject to abandonment, those Assets are not of inconsequential value, or burdensome to the estate. The Court should not authorize the abandonment of those Assets. 7. To the extent that the Court does authorize the abandonment of those Assets, no request has been made by Origin or the Trustee for determination of Origin’s right in those Assets and Warren objects to any determination being made with respect to perfection or other claims of interest by Origin in those Assets. WHEREFORE, PREMISES CONSIDERED, Warren prays that the Notice be found by the Court as not effecting an abandonment of the Assets described in the Notice; that no determination of liens or lien priority be made by the Court based upon the Notice; and for such other and further relief as is just and equitable. Respectfully submitted, By:____/s/Mark J. Petrocchi__________ Mark J. Petrocchi State Bar No. 15851750 GRIFFITH, JAY & MICHEL, LLP 2200 Forest Park Blvd. Fort Worth, TX 76110 Phone (817) 926-2500 Fax (817) 926-2505 mpetrocchi@lawgjm.com ATTORNEYS FOR MITCHELL W. WARREN Response to Notice of Intent to Abandon Page 3 of 4

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CERTIFICATE OF SERVICE The undersigned certifies that he caused a true and correct copy of the foregoing document to be served electronically upon those persons registered on the ECF Filing system of the court on this 17th day of August 2021. __/s/Mark J. Petrocchi_______ Mark J. Petrocchi Response to Notice of Intent to Abandon Page 4 of 4

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