UNITED STATES BANKRUPTCY COURT

SOUTHERN DISTRICT OF FLORIDA

WEST PALM BEACH DIVISION

www.flsb.uscourts.gov

In re: Case No.: 21-13230-EPK

CHRISTI LEE STRAUB Chapter 7

Debtor.

/

CHRISTI LEE STRAUB Adv. No.: 21-01155-EPK

Plaintiff,

v.

MISSOURI HIGHER EDUCATION LOAN 

AUTHORITY, DEPARTMENT OF

EDUCATION OF THE UNITED STATES AND

THE UNIVERSITY OF MINNESOTA.

Defendants.

/

AGREED MOTION TO CONTINUE PRE-TRIAL 

CONFERENCE SCHEDULED FOR JUNE 8, 2022 TO SEPTEMBER 1, 2022,

AND TO RESET ALL CORRESPONDING DISCOVERY DEADLINES

CHRISTI LEE STRAUB (the “Plaintiff”, “Debtor”), by and through undersigned counsel, 

files this Agreed Motion to Continue the Pre-trial Conference Scheduled for June 8, 2022 to 

September 1, 2022, and to Reset All Corresponding Discovery Deadlines (the “Motion”), due to

the Federal Government’s mortarium for deferment of student loan repayments, and in support 

thereof, states as follows:

1. On May 18, 2021, Plaintiff filed an Adversary Proceeding in the instant case against

creditor Missouri Higher Education Loan Authority, Department of Education of the United States

and The University of Minnesota (“Department of Education”) (DE 1).

2. On May 19, 2021, the corresponding summons were issued, and the Notice of PreCase 21-01155-MAM Doc 26 Filed 06/07/22 Page 1 of 3
Trial set the Pre-Trial Conference for October 13, 2021 (DE 2).

3. Based on the Defendant’s request to seek an administrative discharge, this Court 

continued the October Pre-Trial Conference, and set a Status Conference set for March 9, 2022 

(DE 17).

4. During the Status Conference, undersigned counsel informed the Court that the 

Defendant was prepared to move forward with Pre-Trial, which was set for June 8, 2022.

5. The parties began the discovery process by discussing requests and filing their 

corresponding Initial Disclosures (DE 24, 25); however, discovery has not been completed by 

either party.

6. Plaintiff, with consent from Defendant, Department of Education, now seeks to 

continue the Pre-Trial Conference set for June 8, 2022 to September 1, 2022, and to reset all

corresponding discovery deadlines, based on the Federal Government’s moratorium staying 

collection of repayment from student loan borrowers. The moratorium is scheduled to end on 

August 31, 2022.

7. Prior to the initiation of the instant case, the Plaintiff’s monthly payments to 

Defendant were $0.00 based on an income driven repayment plan. During the aforementioned 

moratorium, the monthly payments are $0.00. Therefore, neither party will be prejudiced by 

continuation of the Pre-Trial Conference.

8. The parties agree to the requested relief.

WHEREFORE, Plaintiff respectfully requests this Court i) grant the Motion; ii) continue 

the Pre-Trial Conference to September 1, 2022; iii) reset all corresponding discovery deadlines,

and; iv) provide whatever further relief this Court deems just and proper.

Dated: June 7, 2022

Case 21-01155-MAM Doc 26 Filed 06/07/22 Page 2 of 3
VAN HORN LAW GROUP, P.A.

500 NE 4th St., Suite 200

Fort Lauderdale, FL 33301

Telephone: (954) 765-3166

Facsimile: (954) 756-7103

Email: Chad@cvhlawgroup.com

By: /s/ Chad Van Horn, Esq.

Chad Van Horn, Esq.

Florida Bar No. 64500

Case 21-01155-MAM Doc 26 Filed 06/07/22 Page 3 of 3