UNITED STATES BANKRUPTCY COURT 

SOUTHERN DISTRICT OF FLORIDA 

MIAMI DIVISION 

www.flsb.uscourts.gov 

 

In re: CASE NO.: 18-15499-BKC-AJC 

CHAPTER 7 

WORLD GLOBAL FINANCING, INC., 

Debtor. 

 / 

 

ROSS. R. HARTOG, AS THE CHAPTER 7 

TRUSTEE, 

 

 Plaintiff, ADV. CASE NO.:19-01916-AJC 

v. 

 

MINH TAM TRAN, ADAMS LAM TRAN, 

TAMMY TRAN ATTORNEYS AT LAW, LLP, 

HONG AN LP, VKTL, INC., CHUA, LLC, 

VIET AGENCY, INC., ISMART LEARNING 

CENTER, LLC, K & T SETTLEMENT BRIDGE 

FINANCING, INC., VKLL LP, JC MY LY 

INVESTMENT, INC., HOPE JC FOR VN INC., 

SAIGON JC INVESTMENTS, INC., VIETNAM 

JC INVESTMENTS, INC., MAILY JC 

INVESTMENTS, INC. PHUONG JC 

INVESTMENTS, INC., and HYPERLEDGER 

ASSETS LLC, 

 

 Defendants. 

 / 

PLAINTIFF’S MOTION TO CONTINUE 

PRETRIAL CONFERENCE AND EXTEND RELATED DEADLINES 

Plaintiff, Ross R. Hartog, as Chapter 7 trustee of the bankruptcy estate (the “Estate”) of 

World Global Financing, Inc. (the “Plaintiff” or “Trustee”), through undersigned counsel and 

pursuant to Local Rule 7090-1, moves (the “Motion”) to continue the pretrial conference 

currently scheduled for March 23, 2020 at 10:00 a.m. (the “Pretrial Conference”), and to extend 

all related pretrial deadlines set forth in this Court’s Order Setting Filing and Disclosure 

Case 19-01916-AJC Doc 17 Filed 03/02/20 Page 1 of 4
Requirements for Pretrial and Trial [ECF No. 3](the “Pretrial Order”), and in support thereof 

states: 

1. On December 6, 2019, the Plaintiff filed its complaint [ECF No. 1](the 

“Complaint”), which initiated the instant adversary proceeding.

2. On February 10, 2020, Defendants, Minh-Tam Tran (“T. Tran”), Adams Lam 

Tran (“A. Tran”), Tammy Tran Attorneys at Law, LLP (“Tran Firm”), Hong An LP (“Hong 

An”), VKTL, Inc. (“VKTL”), Chua, LLC (“Chua”), Viet Agency, Inc. (“Viet’), ISmart Learning 

Center, LLC (“ISmart”), K & T Settlement Bridge Financing, Inc. (“K&T”), VKLL LP 

(“VKLL”), JC My Ly Investment, Inc. (“My Ly”), Hope JC For VN, Inc. (“Hope”), Saigon JC 

Investments, Inc. (“Saigon”), Vietnam JC Investments, Inc. (“Vietnam Investments”), Maily JC 

Investments, Inc. (“Maily”), and Phuong JC Investments, Inc. (“Phuong”) (collectively, the 

“Tran Defendants”) filed Defendants’ Answer and Affirmative Defenses. ECF No. 5. 

3. On February 26, 2020, the Clerk of Court entered a default against Defendant 

Hyperledger Assets, LLC (“Hyperledger”). See ECF No. 12. 

4. On March 2, 2020, Hyperledger filed Defendant, Hyperledger Assets, LLC’s 

Motion to Set Aside Default with Incorporated Memorandum of Law [ECF No.15](the “Motion 

to Vacate”), as well as Defendant’s, Hyperledger Assets, LLC’s, Motion to Dismiss and 

Incorporated Memorandum of Law [ECF No. 16](the “Motion to Dismiss”). 

5. Given that the Tran Defendants only answered the Complaint last week, and that 

Hyperledger just filed its Motion to Vacate and Motion to Dismiss today, the Plaintiff 

respectfully requests that the Pretrial Conference be continued for 90 days to allow the Parties to 

complete their preliminary motion practice and engage in discovery. 

6. This is the first request for a continuance of the Pretrial Conference. 

7. None of the parties have filed their initial disclosures. 

Case 19-01916-AJC Doc 17 Filed 03/02/20 Page 2 of 4
8. The Plaintiff certifies that this continuance is not being requested for the purpose 

of delay. 

WHEREFORE, Plaintiff, Ross R. Hartog, as Chapter 7 Trustee of the Bankruptcy Estate 

of World Global Financing, Inc., respectfully requests that this Court enter an Order: (i) 

continuing the Pretrial Conference for a period of 90 days; (ii) extending the corresponding 

deadlines set forth in this Court’s Order Setting Filing and Disclosure Requirements for Pretrial 

and Trial; and (iii) granting such other and further relief as this Court deems just and proper. 

CERTIFICATE OF SERVICE 

 I HEREBY CERTIFY that a true and correct copy of the foregoing was served on March 

2, 2020 via the Court’s CM/ECF to all interested parties registered to receive electronic noticing 

in this case, as noted on the attached Service List. 

 Respectfully submitted, 

MARKOWITZ RINGEL TRUSTY & HARTOG, P.A. 

Counsel for the Plaintiff

9130 S. Dadeland Boulevard, Suite 1800 

Miami, Florida 33156 

Telephone: (305) 670-5000 

Facsimile: (305) 670-5011 

 By: /s/ Alan R. Rosenberg . 

 ALAN R. ROSENBERG 

 Florida Bar No. 92004 

 arosenberg@mrthlaw.com

Case 19-01916-AJC Doc 17 Filed 03/02/20 Page 3 of 4
Ross R. Hartog, as Chapter 7 Trustee v. Minh Tam Tran, et al. 

Adversary Case No. 19-01916-AJC 

Service List 

Electronic Mail Notice List

 Vincent F Alexander vincent.alexander@lewisbrisbois.com, 

claudia.pena@lewisbrisbois.com;ftlemaildesig@lewisbrisbois.com 

 Adrian C. Delancy adelancy@mrthlaw.com, 

ycandia@mrthlaw.com,gruiz@mrthlaw.com,ecfnotices@mrthlaw.com;mrthbkc@gmail.c

om 

 Andres Robles Cruz ARC@roblescruzlaw.com 

 Grace E. Robson grobson@mrthlaw.com, 

jgarey@mrthlaw.com,mrthbkc@gmail.com,lgener@mrthlaw.com,grobson@ecf.courtdriv

e.com 

 Alan R Rosenberg arosenberg@mrthlaw.com, 

gruiz@mrthlaw.com,jgarey@mrthlaw.com,ycandia@mrthlaw.com,mrthbkc@gmail.com 

Case 19-01916-AJC Doc 17 Filed 03/02/20 Page 4 of 4