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Full title: Stipulation By The Roman Catholic Church for the Archdiocese of New Orleans and John Doe Filed by The Roman Catholic Church for the Archdiocese of New Orleans (RE: (related document(s)860 Motion for Relief From Stay filed by Creditor John Doe) (Attachments: # 1 Proposed Order) (Mintz, Mark) (Entered: 06/07/2021)

Document posted on Jun 6, 2021 in the bankruptcy, 3 pages and 0 tables.

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860] NOW INTO COURT, through undersigned counsel, come John Doe (“Doe”) and The Roman Catholic Church of the Archdiocese of New Orleans, the above-captioned debtor and debtor-in-possession (the “Debtor” or “Archdiocese”), who jointly file this Stipulation concerning Sexual Abuse Survivor John Doe’s Motion to Lift Stay [ECF No. 860] (the “Motion to Lift Stay”).FACTUAL BACKGROUND WHEREAS, on September 24, 2019, Doe filed a personal injury tort lawsuit under seal against (1) the Archdiocese, (2) U.S. Central & Southern Province, Society of Jesus, and (3) Jesuit High School of New Orleans in the Civil District Court for the Parish of Orleans. WHEREAS, the Archdiocese subsequently removed Doe’s claims and causes of action asserted in the Doe Lawsuit to the United States District Court of the Eastern of Louisiana (the “District Court”), where the Doe Lawsuit is currently pending as Civil Action No. 20-1368. WHEREAS, on May 10, 2021, Doe filed the Motion to Lift Stay, requesting an order (a) lifting the stay in the Doe Lawsuit to permit Doe to seek dismissal with prejudice of the Archdiocese, or in the alternative, (b) partially lifting the stay in the Doe Lawsuit to allow Doe’s claims to proceed against all defendants other than the Archdiocese.THE ARCHDIOCESE OF NEW ORLEANS CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of this Stipulation is being served (a) on June 7, 2021 by electronic case filing for those parties receiving notice via the Court’s Electronic Case Filing system, and (b) by email or First Class U.S. Mail, postage prepaid, on all other parties requiring service under the Court’s Ex Parte Order Authorizing the Debtor to Limit Notice and Establishing Notice Procedures [ECF No.

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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.1 § § JOINT STIPULATION CONCERNING SEXUAL ABUSE SURVIVOR JOHN DOE’S MOTION TO LIFT STAY [Relates to ECF No. 860] NOW INTO COURT, through undersigned counsel, come John Doe (“Doe”) and The Roman Catholic Church of the Archdiocese of New Orleans, the above-captioned debtor and debtor-in-possession (the “Debtor” or “Archdiocese”), who jointly file this Stipulation concerning Sexual Abuse Survivor John Doe’s Motion to Lift Stay [ECF No. 860] (the “Motion to Lift Stay”). JURISDICTION This Court has jurisdiction over the subject matter of this Stipulation pursuant to 28 U.S.C. § 1334. This is a core proceeding under 28 U.S.C. § 157(b)(2). The statutory and other bases for the relief requested in connection with this Stipulation are 11 U.S.C. §§ 105 and 362 and Rule 4001-1(D) of the Local Rules of the United States Bankruptcy Court for the Eastern District of Louisiana (the “Local Rules”). 1 The last four digits of the Debtor’s federal tax identification number are 8966. The Debtor’s principal place of business is located at 7887 Walmsley Ave., New Orleans, LA 70125.

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FACTUAL BACKGROUND WHEREAS, on September 24, 2019, Doe filed a personal injury tort lawsuit under seal against (1) the Archdiocese, (2) U.S. Central & Southern Province, Society of Jesus, and (3) Jesuit High School of New Orleans in the Civil District Court for the Parish of Orleans. See John Doe v. The Roman Catholic Church of the Archdiocese of New Orleans, et al., Civil Action No. 19-10040, Civil District Court for the Parish of Orleans (the “Doe Lawsuit”). WHEREAS, on May 1, 2020, the Archdiocese filed a voluntary petition for relief under chapter 11 of title 11 of the United States Code (the “Bankruptcy Code”), commencing the above-captioned case (the “Chapter 11 Case”). WHEREAS, the Archdiocese subsequently removed Doe’s claims and causes of action asserted in the Doe Lawsuit to the United States District Court of the Eastern of Louisiana (the “District Court”), where the Doe Lawsuit is currently pending as Civil Action No. 20-1368. WHEREAS, on November 20, 2020, the District Court entered an Order that stayed and administratively closed the Doe Lawsuit during the pendency of the Archdiocese’s bankruptcy proceedings. WHEREAS, on May 10, 2021, Doe filed the Motion to Lift Stay, requesting an order (a) lifting the stay in the Doe Lawsuit to permit Doe to seek dismissal with prejudice of the Archdiocese, or in the alternative, (b) partially lifting the stay in the Doe Lawsuit to allow Doe’s claims to proceed against all defendants other than the Archdiocese. WHEREAS, Doe and the Debtor have reached an agreement to resolve the Motion to Lift Stay. AGREEMENT NOW, THEREFORE, the parties stipulate and agree as follows:

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IT IS STIPULATED that the automatic stay imposed by 11 U.S.C. § 362(a) is partially lifted to allow Doe to prosecute, and the District Court to adjudicate, a motion to dismiss the Archdiocese with prejudice from the Doe Lawsuit. IT IS FURTHER STIPULATED that this agreement shall remain in effect until confirmation of a plan in this Chapter 11 Case. Respectfully submitted, /s/ Mark A. Mintz_______________________ /s/ Kristi S. Schubert _________________ R. PATRICK VANCE (#13008) FRANK E. LAMOTHE, III (#07945) ELIZABETH J. FUTRELL (#05863) KRISTI S. SCHUBERT (#34870) EDWARD D. WEGMANN (#13315) JULIEN G. LAMOTHE (#38313) MARK A. MINTZ (#31878) Lamothe Law Firm, LLC LAURA F. ASHLEY (#32820) 400 Poydras Street, Suite 1760 Jones Walker LLP New Orleans, LA 70130 201 St. Charles Avenue, 51st Floor Telephone: (504) 704-1414 New Orleans, LA 70170 Email: felamothe@lamothefirm.com Telephone: (504) 582-8000 Email: kschubert@lamothefirm.com Facsimile: (504) 589-8260 Email: jlamothe@lamothefirm.com Email: pvance@joneswalker.com Email: efutrell@joneswalker.com ATTORNEYS FOR JOHN DOE Email: dwegmann@joneswalker.com Email: mmintz@joneswalker.com Email: lashley@joneswalker.com ATTORNEYS FOR THE ROMAN CATHOLIC CHURCH OF THE ARCHDIOCESE OF NEW ORLEANS CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of this Stipulation is being served (a) on June 7, 2021 by electronic case filing for those parties receiving notice via the Court’s Electronic Case Filing system, and (b) by email or First Class U.S. Mail, postage prepaid, on all other parties requiring service under the Court’s Ex Parte Order Authorizing the Debtor to Limit Notice and Establishing Notice Procedures [ECF No. 22], to be sent by Donlin Recano & Company, Inc. (“DRC”). DRC shall file a certificate of service to that effect once service is completed. /s/ Mark A. Mintz Mark A. Mintz

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