Richard D. Scott (Va. Bar No. 44527)

Law Office of Richard D. Scott

302 Washington Avenue, SW

Roanoke, Virginia 24016

(540) 400-7997

(540) 491-9465 (Facsimile)

richard@rscottlawoffice.com

Counsel for PACCAR Financial Corp.

IN THE UNITED STATES BANKRUPTCY COURT

FOR THE EASTERN DISTRICT OF VIRGINIA

Alexandria Division

In re: ) Chapter 11

)

GLOBAL ENVIRONMENTAL SOLUTIONS, ) Case No. 19-11583-BFK

INC., )

)

Debtor )

)

)

PACCAR FINANCIAL CORP., )

)

Movant, )

)

v. )

)

GLOBAL ENVIRONMENTAL SOLUTIONS, )

INC., )

)

Respondent. )

AMENDED NOTICE OF PACCAR FINANCIAL CORP.’S

MOTION FOR RELIEF FROM THE AUTOMATIC STAY OR,

ALTERNATIVELY, FOR ADEQUATE PROTECTION

(Five Peterbilt Tractors)

PACCAR Financial Corp. (“PACCAR”), by counsel, has filed a motion with the Court to 

seek relief from the automatic stay to permit it to exercise its rights with respect to five (5) Peterbilt 

tractors.

Your rights may be affected. You should read these papers carefully and discuss 

them with your attorney, if you have one in this bankruptcy case. (If you do not have an 

attorney, you may wish to consult with one.)

If you do not want the Court to grant the relief sought in this motion, or if you want the 

Court to consider your views on the motion, then on or before June 17, 2019 at 5:00 p.m. (as set 

forth in the Court’s Order Granting Motion for Expedited Hearing entered June 6, 2019), you or 

your attorney must:

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1. File a written response and supporting memorandum, pursuant to Local Bankruptcy 

Rule 9013-1(H), explaining your position with the Court at the following address: Clerk of Court, 

United States Bankruptcy Court, 200 S. Washington Street, Alexandria, VA 22314-5405, and 

serve a copy on the movant at the address specified below. Unless a written response is filed and 

served by the date specified, the Court may deem opposition waived, treat the motion as conceded, 

and issue an order granting the requested relief.

If you mail your response to the court for filing, you must mail it early enough so the court 

will receive it on or before the date stated above. 

2. Attend the preliminary hearing scheduled to be held on June 19, 2019, at 9:30 a.m.

in Courtroom I (Second Floor) at the United States Bankruptcy Court for the Eastern District of 

Virginia, Alexandria Division, 200 S. Washington Street, Alexandria, VA 22314.

If you or your attorney do not take these steps, the court may decide that you do not 

oppose the relief sought in the motion or objection and may enter an order granting that 

relief.

A copy of any written responses must be sent to:

Richard D. Scott, Esq.

Law Office of Richard D. Scott

302 Washington Avenue SW

Roanoke, VA 24016

Daniel M. Press, Esq.

Chung & Press, P.C.

6718 Whittier Avenue, Suite 200

McLean, VA 22101

Jack Frankel

Office of the U.S. Trustee, Region 4

1725 Duke Street, Suite 650

Alexandria, VA 22314

If you or your attorney do not take these steps, the Court may decide that you do not oppose 

the relief sought in the motion and may enter an order granting that relief.

Date: June 6, 2019 PACCAR Financial Corp.

By:/s/ Richard D. Scott

Counsel

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Richard D. Scott (Va. Bar No. 44527)

Law Office of Richard D. Scott

302 Washington Avenue, SW

Roanoke, Virginia 24016

(540) 400-7997

(540) 491-9465 (Facsimile)

richard@rscottlawoffice.com

Counsel for PACCAR Financial Corp.

CERTIFICATE OF SERVICE

I hereby certify that on June 6, 2019, a true copy of the foregoing Amended Notice was 

electronically filed with the Clerk of the Court for the U.S. Bankruptcy Court for the Eastern 

District of Virginia, using the Court’s CM/ECF system, which served electronically all registered 

ECF users who have filed notices of appearance in this matter and mailed, and by U.S. Mail, first 

class, postage prepaid, on June 6, 2019 to all creditors and parties in interest on the mailing matrix 

on file with the Eastern District of Virginia Bankruptcy Court.

/s/ Richard D. Scott

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