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Full title: Motion to Expedite Hearing On Freeman's Motion for Relief from Automatic Stay (RE: related document(s)936 Motion for Relief From Stay filed by Interested Party Angela Freeman) Filed by Jeremy Gettes of Gertler Law Firm on behalf of Angela Freeman (Gettes, Jeremy) (Entered: 07/16/2021)

Document posted on Jul 15, 2021 in the bankruptcy, 2 pages and 0 tables.

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THE ARCHDIOCESE OF NEW ORLEANS CHAPTER 11 DEBTOR EX PARTE MOTION FOR EXPEDITED HEARING ON ANGELA FREEMAN’SFOR RELIEF FROM AUTOMATIC STAY Angela Freeman hereby files this Ex Parte Motion for Expedited Hearing on her Motion forRelief from Automatic Stay. This Court has jurisdiction to consider this Motion pursuant to 28 U.S.C. § 157 and§ 1334.WHEREFORE, Freeman respectfully requests that the Court: (I) enter an Order insubstantially the same form as the attached, setting the Motion for Relief from Automatic Stay forexpedited hearing, and (ii) provide such other relief as the Court deems appropriate and just.This is to certify that a copy of the foregoing Motion was served on July 15, 2021 upon allparties by electronic case filing for those parties receiving notice via the Court’s Electronic CaseFiling System. /s/

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UNITED STATES BANKRUPTCY COURT EASTERN DISTRICT OF LOUISIANA IN RE: CASE NO. 20-10846 THE ROMAN CATHOLIC CHURCH OF SECTION “A” THE ARCHDIOCESE OF NEW ORLEANS CHAPTER 11 DEBTOR EX PARTE MOTION FOR EXPEDITED HEARING ON ANGELA FREEMAN’S MOTION FOR RELIEF FROM AUTOMATIC STAY Angela Freeman hereby files this Ex Parte Motion for Expedited Hearing on her Motion forRelief from Automatic Stay. In further support of the Motion for Expedited Hearing, Freemanrespectfully states: JURISDICTION AND VENUE 1. This Court has jurisdiction to consider this Motion pursuant to 28 U.S.C. § 157 and§ 1334. This is a core proceeding pursuant to 28 U.S.C. § 157(b)(2). 2. This Court has the authority to grant the relief sought pursuant to 11 U.S.C. § 362(d). 3. Venue is proper in this Court pursuant to 28 U.S.C. §§ 1408 and 1409. REQUEST FOR EXPEDITED RELIEF AND ARGUMENT IN SUPPORT 4. A jury trial is currently set to begin in state court on August 9, 2021. Freeman filedthe Motion for Relief from Automatic Stay so that trial may begin on that date. 5. The Debtor will not be prejudiced. Freeman requests a deadline of July 21, 2021 forinterested parties to file an opposition. 6. No discovery or other external efforts need to be performed by Freeman or Debtorbefore the hearing. 7. Freeman will be prejudiced if the motion is not granted because she may lose her

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state court trial date. 8. Counsel for the Debtor and counsel for the Apostolates do not oppose a hearing dateof July 22, 2021. WHEREFORE, Freeman respectfully requests that the Court: (I) enter an Order insubstantially the same form as the attached, setting the Motion for Relief from Automatic Stay forexpedited hearing, and (ii) provide such other relief as the Court deems appropriate and just. Dated: July 15, 2021 Respectfully submitted, GERTLER LAW FIRM, LLP /s/ Louis L. Gertler LOUIS L. GERTLER (LSBA #23091) JEREMY N. GETTES (LSBA #38231) 935 Gravier Street, Suite 1900 New Orleans, Louisiana 70112 Telephone: (504) 581-6411 Facsimile: (504) 581-6568 Emails: lgertler@gertlerfirm.com jgettes@gertlerfirm.com Attorneys for Angela Freeman CERTIFICATE OF SERVICE This is to certify that a copy of the foregoing Motion was served on July 15, 2021 upon allparties by electronic case filing for those parties receiving notice via the Court’s Electronic CaseFiling System. /s/ Jeremy Gettes Jeremy Gettes 2

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