Matthew F. Wegner

9500 Ray White Road

Suite 200

Fort Worth, TX 76244

817-494-3344

matthew@attorneywegner.com

IN THE UNITED STATES BANKRUPTCY COURT

FOR THE NORTHERN DISTRICT OF TEXAS

FORT WORTH DIVISION

IN RE: § CASE NO: 24-40703

§

John Meritt §

Loretta Meritt §

Debtors §

§

§

OBJECTION TO PROOF OF CLAIM NO. 03

FILED BY TEXAS WORKFORCE COMMISSION

NO HEARING WILL BE CONDUCTED HEREON UNLESS A WRITTEN

RESPONSE IS FILED WITH THE CLERK OF THE UNITED STATES

BANKRUPTCY COURT AT ELDON B. MAHON U.S. COURTHOUSE, 501 W.

TENTH STREET, FORT WORTH, TX 76102-3643 BEFORE THE CLOSE OF

BUSINESS ON April 17, 2024, WHICH IS AT LEAST 30 DAYS FROM THE

DATE OF SERVICE HEREOF.

ANY RESPONSE SHALL BE IN WRITING AND FILED WITH THE CLERK,

AND A COPY MUST BE SERVED UPON COUNSEL FOR THE MOVING

PARTY PRIOR TO THE DATE AND TIME SET FORTH HEREIN. IF A

RESPONSE IS FILED A HEARING WILL BE HELD WITH NOTICE ONLY

TO THE OBJECTING PARTY.

IF NO HEARING ON SUCH NOTICE OR MOTION IS TIMELY

REQUESTED, THE RELIEF REQUESTED SHALL BE DEEMED TO BE

UNOPPOSED, AND THE COURT MAY ENTER AN ORDER GRANTING

THE RELIEF SOUGHT OR THE NOTICED ACTION MAY BE TAKEN.

TO THE HONORABLE JUDGE MARK X. MULLIN, UNITED STATES BANKRUPTCY

JUDGE:

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John and Loretta Meritt Debtors, file this Objection to Proof of Claim No. 03 filed by

Texas Workforce Commission, and would respectfully show as follows:

1. On February 29, 2024, the Debtors filed a voluntary petition in this Court for

relief under chapter 13 of the United States Bankruptcy code.

2. The Court has jurisdiction over this matter under 28 U.S.C. §§ 1334 and 157. This

matter constitutes a “core” proceeding within the meaning of 28 U.S.C. § 157(b)(2).

3. Texas Workforce Commission, filed a proof of claim asserting a unsecured claim

in the amount of $31,982.00, which was docketed as Claim No. 03 on the Court’s ECF claims

register for this case (the “Subject Claim”).

4. Debtor Objects to Proof of Claim on the basis She reported to unemployment

every time she received a job and then was subsequently let go during the time period of the

claim. She would then reapply for unemployment. She did not receive any funds from

unemployment while she was employed during that time period.

WHEREFORE, PREMISES CONSIDERED the Debtor requests that the Court disallow

Claim No. 03 of Texas Workforce Commission, and for such other and further relief to which she

may show herself justly entitled.

Respectfully submitted,

/s/Matthew F. Wegner

Matthew F. Wegner

SBOT 24031234

9500 Ray White Road

Suite 200

Fort Worth, TX 76244

817-494-3344

matthew@attorneywegner.com

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CERTIFICATE OF SERVICE

I hereby certify that a true and correct copy of the foregoing document was served

concurrently with the filing of the same (a) by ECF upon all persons who have filed ECF

appearances in this case, including counsel of record for the Creditor, the Trustee, The office of

the United States Trustee, and all persons and entities requesting notice under Fed.R. Civ. P.

2002(m) and (b) by first class mail, postage prepaid on the following:

Texas Workforce Commission

Regulatory Integrity Division, Collectio

101 E 15th Street, Room 556

Austin, TX 78778-0001

/s/Matthew F. Wegner

Matthew F. Wegner

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