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UNITED STATES BANKRUPTCY COURT 

SOUTHERN DISTRICT OF FLORIDA 

FORT LAUDERDALE DIVISION 

www.flsb.uscourts.gov 

In re: Case No. 21-13230-EPK 

Christi Lee Straub Chapter 7 

Debtor-in-Possession. 

_____________________________________/ 

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 OCTOBER 13, 2021 

Christi Lee Straub (the “Plaintiff”, “Debtor”), by and through undersigned counsel, files 

this Agreed Motion to Continue the Pre-trial Conference Scheduled for October 13, 2021, and 

respectfully request the Court to enter an order continuing the Pre-trial Conference for thirty (30) 

days, and in support thereof, state 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 Pretrail set the Pre-trial Conference for October 13, 2021. (DE 2)

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3. On September 23, 2021, Department of Education filed its answer to Plaintiff’s

Adversary Proceeding. (DE 14) 

4. The parties have been in communication, and are trying to resolve the pending

matter. 

5. Plaintiff requests that the Court enters an order continuing the Pre-trial Conference

for the next thirty (30) days. 

6. Counsel for the Department of Education, Raychelle Tasher, Esq. has consented to

the continuance.

7. A proposed Order continuing the hearing is attached hereto as Exhibit “A”.

WHEREFORE, Debtor respectfully requests the Court to grant the Agreed Motion, and 

to continue the Pre-trial Conference scheduled for October 13, 2021 for the thirty (30) days, and 

for any further relief this Court deems proper. 

Dated: October 12, 2021 

VAN HORN LAW GROUP, P.A. 

330 N Andrews Ave., Suite 450 

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 

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Exhibit “A” 

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UNITED STATES BANKRUPTCY COURT 

SOUTHERN DISTRICT OF FLORIDA 

FORT LAUDERDALE DIVISION 

www.flsb.uscourts.gov 

In re: Case No. 21-13230-EPK 

 

Christi Lee Straub Chapter 7 

 

 Debtor-in-Possession. 

_____________________________________/ 

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 ORDER GRANTING AGREED MOTION TO CONTINUE 

PRE-TRIAL CONFERENCE SCHEDULED FOR OCTOBER 13, 2021 

 THIS MATTER came before the Court upon the Agreed Motion to Continue Pre-trial 

Conference Scheduled for October 13, 2021 (DE XX) (the “Motion”), and the Court, having 

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reviewed the Motion, noting the agreement of the parties, being otherwise fully advised finds good 

cause exists to continue the Pre-trial Conference 

IT IS THEREFORE ORDERED: 

1. The Agreed Motion to Continue Pre-trial Conference scheduled for October 13, 

2021 is GRANTED. 

2. The Pre-trial Conference has been continued for 

_____________________________ (“Continued Pretrial Conference Date”) by VIDEO via Zoom 

Meeting.

3. All deadlines in the Order Setting Filing and Disclosure Requirements for Pretrial 

and Trial (DE 3) shall be continued and calculated based on the Continued Pretrial Conference 

Date.

4. Registration for remote attendance for the hearing mey be arranged online at 

https://www.zoomgov.com/meeting/register/vJIsduGsrTouGn7Udkhqe_ZF90qPJ3uM95E. 

# # # 

Submitted by: 

Chad T. Van Horn, Esq. 

Florida Bar No. 64500 

VAN HORN LAW GROUP, P.A. 

330 N Andrews Ave., Suite 450 

Fort Lauderdale, FL 33301 

Telephone: (954) 765-3166 

Facsimile: (954) 756-7103 

Email: Chad@cvhlawgroup.com 

Chad Van Horn, Esq. is hereby directed to provide a conformed copy of this Order to all partiesin-interest and to file a Certificate of Service as to same.

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