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Full title: Unopposed Motion to Extend Time for Deadline for Filing Complaint to Determine Dischargability of Debt Filed by Glenn K. Schreiber of U.S. Attorney's Office on behalf of United States of America/Dept.of Justice (Schreiber, Glenn) (Entered: 05/26/2021)

Document posted on May 25, 2021 in the bankruptcy, 3 pages and 0 tables.

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NOW INTO COURT, comes the United States of America, a creditor and party in interest in the above-styled proceeding, and pursuant to Bankruptcy Rule 4007(c), respectfully moves this Honorable Court for an additional sixty (60) day extension of time through July 27, 2021, within which the United States may file a complaint for determination of the dischargeability of a debt.On May 1, 2020 (the “Petition Date”), the above-referenced debtor (“Debtor”) filed a voluntary petition for relief under chapter 11 of title 11 of the United States Code (the “Bankruptcy Code”) with the United States Bankruptcy Court for the Eastern District of Louisiana commencing this chapter 11 case.Prior to the Petition Date, the Debtor was named as a defendant in a qui tam action filed in the United States District Court for the Eastern District of Louisiana captioned United States ex rel.Although the United States believes the filing of a non-dischargeability complaint is unnecessary, out of an abundance of caution, the United States seeks entry of an order, substantially in the form attached hereto as Exhibit A (the “Order”), extending the deadline for the United States to file a complaint to determine the dischargeability of a debt for a period of sixty (60) days, from Friday, May 28, 2021, through and including Tuesday, July 27, 2021, without prejudice to further extensions.Nothing in this Motion or the proposed Order is intended to constitute a determination or admission that sections 523 or 1141(d)(6) of the Bankruptcy Code or Rule 4007 of the Federal Rules of Bankruptcy Procedure apply to any debt arising from the Civil Action, or that the United States is required to file a complaint to determine the non-dischargeability of a debt under 11 U.S.C. § 1141(d)(6).

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UNITED STATES BANKRUPTCY COURT EASTERN DISTRICT OF LOUISIANA IN RE: § § CASE NO. 20-10846 THE ROMAN CATHOLIC CHURCH § OF THE ARCHDIOCESE OF NEW § SECTION “A” ORLEANS, § § CHAPTER 11 DEBTOR. § SIXTH UNOPPOSED MOTION TO EXTEND DEADLINE FOR FILING COMPLAINT TO DETERMINE DISCHARGEABILITY OF DEBT NOW INTO COURT, comes the United States of America, a creditor and party in interest in the above-styled proceeding, and pursuant to Bankruptcy Rule 4007(c), respectfully moves this Honorable Court for an additional sixty (60) day extension of time through July 27, 2021, within which the United States may file a complaint for determination of the dischargeability of a debt. In support of this motion, the undersigned states as follows: 1. On May 1, 2020 (the “Petition Date”), the above-referenced debtor (“Debtor”) filed a voluntary petition for relief under chapter 11 of title 11 of the United States Code (the “Bankruptcy Code”) with the United States Bankruptcy Court for the Eastern District of Louisiana commencing this chapter 11 case. The Debtor remains in possession of its property and is managing its business as a debtor in possession pursuant to §§ 1107(a) and 1108 of the Bankruptcy Code. 2. On May 20, 2020, the United States Trustee appointed a Committee of Unsecured Creditors. [Docket #94]. On June 10, 2020, the United States Trustee filed a Notice of Appointment of Reconstituted Creditors Committee to replace Hancock Whitney Bank (as bond trustee) with TMI Trust Company. [Docket #151].

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3. Prior to the Petition Date, the Debtor was named as a defendant in a qui tam action filed in the United States District Court for the Eastern District of Louisiana captioned United States ex rel. Robert Romero v. [SEALED], Roman Catholic Church of the Archdiocese of New Orleans, and [SEALED], pursuant to the False Claims Act, 31 U.S.C. § 3730(b) (the “Civil Action”). See Docket #103. 4. The Civil Action may give rise to a debt owed to the United States, which the United States maintains is automatically non-dischargeable under 11 U.S.C. § 1141(d)(6). The Debtor denies any liability in connection with the Civil Action. 5. The current deadline for objecting to the dischargeability of this United States debt is May 28, 2021. See 11 U.S.C. § 523(c) and Record Doc. #790 [the previous Extension Order]. 6. Although the United States believes the filing of a non-dischargeability complaint is unnecessary, out of an abundance of caution, the United States seeks entry of an order, substantially in the form attached hereto as Exhibit A (the “Order”), extending the deadline for the United States to file a complaint to determine the dischargeability of a debt for a period of sixty (60) days, from Friday, May 28, 2021, through and including Tuesday, July 27, 2021, without prejudice to further extensions. 7. Nothing in this Motion or the proposed Order is intended to constitute a determination or admission that sections 523 or 1141(d)(6) of the Bankruptcy Code or Rule 4007 of the Federal Rules of Bankruptcy Procedure apply to any debt arising from the Civil Action, or that the United States is required to file a complaint to determine the non-dischargeability of a debt under 11 U.S.C. § 1141(d)(6). 8. The United States contacted Debtor’s counsel about the relief sought herein and was advised that the Debtor does not oppose an extension of the deadline for the United States.

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9. WHEREFORE, the United States of America requests an extension of time, through July 27, 2021, in which it may file a complaint to determine the dischargeability of a debt. Respectfully submitted, DUANE A. EVANS UNITED STATES ATTORNEY /s/Glenn K. Schreiber GLENN K. SCHREIBER Assistant United States Attorney U.S. Attorney’s Office (E.D. La.) 650 Poydras Street – Suite 1600 New Orleans, Louisiana 70130 Telephone: (504) 680-3093 glenn.schreiber@usdoj.gov OF COUNSEL: Mary A. Schmergel Senior Trial Counsel Commercial Litigation Branch U.S. Department of Justice 1100 L Street, NW, Room 7110 Washington, DC 20005 Tel: (202) 307-0183 mary.schmergel@usdoj.gov CERTIFICATE OF SERVICE I hereby certify that on this 26th day of May, 2021, a copy of the Sixth Unopposed Motion to Extend Deadline for Filing Complaint to Determine Dischargeability of Debt was filed with the Clerk of Court by using the CM/ECF system which will send a notice of electronic filing to all parties of record. /s/ Glenn K. Schreiber GLENN K. SCHREIBER Assistant United States Attorney

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