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Full title: Response (Filed By T. Murt Byrne, DVM ).(Related document(s):557 Generic Motion, 564 Response) (Odell, Brad) (Entered: 05/28/2021)

Document posted on May 27, 2021 in the bankruptcy, 2 pages and 0 tables.

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OBJECTION PROCEDURES AND (II) FINALLY RESOLVING INTEREST RATE APPLICABLE TO CERTAIN CLAIMS TO THE HONORABLE CHRISTOPHER M. LOPEZ, U.S. BANKRUPTCY JUDGE: COMES NOW, Dr. Timothy Murt Byrne (“Dr. Byrne”), an unsecured creditor of the Debtors, and files this Joinder to the Response to Trustee’s Motion for Order (I)Likewise, Dr. Byrne joins in the Response and states that his claim and interest paid thereon should not be limited to the federal judgment rate, but instead should be paid interest in accordance with In re Ultra Petroleum Corp., the Notes, and state law.Therefore, Dr. Byrne opposes the relief requested in the Trustee’s motion to limit interest on Dr. Byrne’s unsecured claims to the federal judgment rate.WHEREFORE, PRESMISES CONSDIERED, Dr. Byrne respectfully prays that the Court enter an order approving the Trustee’s requested Omnibus Claims Objection Procedures, denying the Trustee’s request to set the interest rate on all general unsecured creditors’ claims at the federal judgment rate, set the interest rate on general unsecured claims, including Dr. Byrne’s claims, according to In re Ultra Petroleum Corp. and state law, and to grant him such other and further relief to which he may be entitled. This is to certify that a true and correct copy of the foregoing Joinder was served electronically on this 28th day of May, 2021 on Jay Ong, counsel for the Trustee, and on all other parties in interest receiving electronic notice through the Court’s CM/ECF system.

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IN THE UNITED STATES BANKRUPTCY COURT FOR THE SOUTHERN DISTRICT OF TEXAS HOUSTON DIVISION In Re: § § Jointly Administered VETERINARY CARE, INC. § § Case No. 19-35736-CML-11 DBA VITALPET, et al., § (Chapter 11) Debtors. § JOINDER IN RESPONSE TO TRUSTEE’S MOTION FOR ORDER (I) APPROVING OMNIBUS CLAIM OBJECTION PROCEDURES AND (II) FINALLY RESOLVING INTEREST RATE APPLICABLE TO CERTAIN CLAIMS TO THE HONORABLE CHRISTOPHER M. LOPEZ, U.S. BANKRUPTCY JUDGE: COMES NOW, Dr. Timothy Murt Byrne (“Dr. Byrne”), an unsecured creditor of the Debtors, and files this Joinder to the Response to Trustee’s Motion for Order (I) Approving Omnibus Claim Objection Procedures and (II) Finally Resolving Interest Rate Applicable to Certain Claims (“Response”) [Dkt. No. 564] filed by similarly situated unsecured creditors, James Kelly, David Fernandez, Glenn Peterman, and Willie Janik. 1. Dr. Byrne holds two unsecured claims evidenced by notes (collectively, the “Notes”) against the Debtors. The Notes arise from the sale of Dr. Byrne’s practice to Debtors pre-petition. 2. Dr. Byrne joins in the Response and states that he does not oppose the Trustee’s request for Omnibus Claim Objection Procedures. 3. Likewise, Dr. Byrne joins in the Response and states that his claim and interest paid thereon should not be limited to the federal judgment rate, but instead should be paid interest in accordance with In re Ultra Petroleum Corp., the Notes, and state law. Therefore, Dr. Byrne opposes the relief requested in the Trustee’s motion to limit interest on Dr. Byrne’s unsecured claims to the federal judgment rate.

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WHEREFORE, PRESMISES CONSDIERED, Dr. Byrne respectfully prays that the Court enter an order approving the Trustee’s requested Omnibus Claims Objection Procedures, denying the Trustee’s request to set the interest rate on all general unsecured creditors’ claims at the federal judgment rate, set the interest rate on general unsecured claims, including Dr. Byrne’s claims, according to In re Ultra Petroleum Corp. and state law, and to grant him such other and further relief to which he may be entitled. Respectfully submitted, MULLIN HOARD & BROWN, L.L.P. P.O. Box 2585 Lubbock, Texas 79408-2585 Telephone: (806) 765-7491 Facsimile: (806) 765-0553 Email: drl@mhba.com /s/ Brad W. Odell_________________ David R. Langston, SBN: 11923800 Brad W. Odell, SBN: 24065839 Attorneys for T. Murt Byrne CERTIFICATE OF SERVVICE This is to certify that a true and correct copy of the foregoing Joinder was served electronically on this 28th day of May, 2021 on Jay Ong, counsel for the Trustee, and on all other parties in interest receiving electronic notice through the Court’s CM/ECF system. /s/ Brad W. Odell_____________________ Brad W. Odell

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