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UNITED STATES BANKRUPTCY COURT

SOUTHERN DISTRICT OF FLORIDA

WEST PALM BEACH DIVISION

www.flsb.uscourts.gov

In re: 

CHRISTI LEE STRAUB, Case No.: 21-13230-EPK 

Chapter 7

Debtor.

/

CHRISTI LEE STRAUB,

Plaintiff,

vs. Adv. No.: 21-01155-EPK

MISSOURI HIGHER EDUCATION 

LOAN AUTHORITY and THE UNITED 

STATES DEPARTMENT OF

EDUCATION and THE UNIVERSITY 

OF MINNESOTA,

Defendants,

/

PLAINTIFF’S EX-PARTE MOTION FOR (I) ORDER DIRECTING CLERK

TO ISSUE ALIAS SUMMONS FOR ALL DEFENDANTS; AND

(II) TO CONTINUE STATUS CONFERENCE AND ALL RELATED DEADLINES

The Plaintiff/Debtor, CHRISTI LEE STRAUB, by and through undersigned counsel, files 

this Ex-Parte Motion for (I) Order Directing Clerk to Issue Alias Summons for All Defendants; and 

(II) to Continue Status Conference and All Related Deadlines (the “Motion”), pursuant to Local 

Rules 7004-2 and 7090.1, and requests that this Court (i) enter an Order directing the Clerk to issue 

an Alias Summons for all Defendants; and (ii) continue the status conference and all related 

deadlines. In support, Plaintiff states as follows:

1. On May 18, 2021, Plaintiff filed the Adversary Complaint (DE 1) (the “Complaint”)

against Defendants Missouri Higher Education Loan Authority; The United States Department of 

Education; and the University of Minnesota (collectively, the “Defendants”).

Case 21-01155-MAM Doc 4 Filed 07/15/21 Page 1 of 4
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2. The Summons and Notice of Status Conference in an Adversary Proceeding was 

docketed on May 19, 2021 (DE 2) (the “Summons”) setting the deadline for Defendants to respond 

to the Complaint to June 23, 2021.

3. The Status Conference is currently set for August 11, 2021 at 9:30 a.m. (see DE 2).

4. Service of the Complaint, Summons, and Order Setting Status Conference and 

Establishing Procedures and Deadlines (DE 3) have not yet been accomplished.

5. The Plaintiff respectfully requests that the Court issue an Alias Summons to the 

Defendants.

6. This request is made in good faith and not for the purpose of delay. Accordingly, 

the Plaintiff believes the approval of such relief is in the best interests of the Debtor’s bankruptcy 

estate, its creditors and all interested parties.

WHEREFORE, Plaintiff respectfully requests that this Court enter an Order, in the form 

attached as Exhibit “A” (i) granting this Motion; (ii) directing the Clerk to issue an Alias Summons 

to the Defendants; (iii) continuing the Status Conference and all related deadlines for sixty (60) 

days in accordance with the Court availability, or to such other date as may be deemed appropriate 

by the Court; and (iv) such other and further relief as the Court deems just and proper.

Respectfully submitted on this 15th day of July, 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” – PROPOSED ORDER

UNITED STATES BANKRUPTCY COURT

SOUTHERN DISTRICT OF FLORIDA

WEST PALM BEACH DIVISION

www.flsb.uscourts.gov

In re: 

CHRISTI LEE STRAUB, Case No.: 21-13230-EPK 

Chapter 7

Debtor.

/

CHRISTI LEE STRAUB,

Plaintiff,

vs. Adv. No.: 21-01155-EPK

MISSOURI HIGHER EDUCATION 

LOAN AUTHORITY and THE UNITED 

STATES DEPARTMENT OF

EDUCATION and THE UNIVERSITY 

OF MINNESOTA,

Defendants,

/

ORDER GRANTING PLAINTIFF’S EX-PARTE MOTION FOR (I) ORDER

DIRECTING CLERK TO ISSUE ALIAS SUMMONS FOR ALL DEFENDANTS; AND

(II) CONTINUING STATUS CONFERENCE AND ALL RELATED DEADLINES (DE XX)

THIS MATTER, came before the Court upon the Plaintiff’s Ex-Parte Motion for (I) Order 

Case 21-01155-MAM Doc 4 Filed 07/15/21 Page 3 of 4
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Directing Clerk to Issue Alias Summons for All Defendants; and (II) to Continue Status Conference 

and All Related Deadlines (the “Motion”) (DE XX). The Court, having reviewed the Motion, finds 

that good cause exists to grant the Motion.

IT IS THEREFORE ORDERED:

1. The Motion is GRANTED.

2. The Clerk is directed to issue an Alias Summons to all Defendants.

3. The Status Conference currently scheduled for August 11, 2021 at 9:30 a.m. is 

continued and rescheduled for Wednesday, October 13, 2021, at 9:30 a.m. through Video 

Conference by Zoom for Government.

4. The Status Conference in this adversary proceeding will take place only by video 

conference. To participate in the hearing, you must register in advance no later than 3:00 p.m., one 

business day before the date of the hearing. To register, click on or enter the following registration 

link in a browser: 

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

5. All Status Conference Deadlines are reset relative to the newly scheduled Status 

Conference.

# # #

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 directed to provide a copy of this signed Order to all parties of record and 

to file a Certificate of Service conforming with Local Rule 2002-1(F).

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