Debtors’ Motion For Joint Administration

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MULLIN HOARD & BROWN, L.L.P.

David R. Langston, SBN: 11923800

P.O. Box 2585

Lubbock, Texas 79408-2585

Telephone: 806-765-7491

Telefax: 806-765-0553

Email: drl@mhba.com

Attorneys for Debtor, MP Southpark 

Pharmacy, LLC d/b/a Myers Drug and

Micah and Krystan Pratt

IN THE UNITED STATES BANKRUPTCY COURT

FOR THE NORTHERN DISTRICT OF TEXAS

LUBBOCK DIVISION

IN RE:

MP SOUTHPARK PHARMACY, 

LLC d/b/a MYERS DRUG

Debtor.

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Case No. 24-50146-RLJ-11

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IN RE:

MICAH G. PRATT and wife, 

KRYSTAN L. PRATT

Debtors.

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Case No. 24-50147-RLJ-11

DEBTORS’ MOTION FOR JOINT ADMINISTRATION 

TO THE HONORABLE ROBERT L. JONES, U.S. Bankruptcy Judge:

NOW COMES, MICAH G. PRATT and wife, KRYSTAN L. PRATT (the 

“Debtors”) the Debtors in the above-referenced bankruptcy proceeding, and files this their

Motion For Joint Administration of its Chapter 11 bankruptcy case with that of the Chapter 

11 proceeding of their affiliate, MP SOUTHPARK PHARMACY, LLC d/b/a MYERS 

DRUG, (Case No. 24-50146-RLJ-11), and in support of such Motion would respectfully 

show the Court as follows:

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Debtors’ Motion For Joint Administration

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I.

Pursuant to 11 U.S.C. § 302 and Bankruptcy Rule 1015 the Debtor wishes to jointly 

administer its case with that of MP SOUTHPARK PHARMACY, LLC d/b/a MYERS 

DRUG, (Case No. 24-50146-RLJ-11). This request for consolidation is to allow for a joint 

administration of the two cases. The Debtors would submit that this Motion is filed in 

good faith and is in the best interest of all of the parties.

II.

The Debtors, MICAH G. PRATT and wife, KRYSTAN L. PRATT would show 

that MP SOUTHPARK PHARMACY, LLC d/b/a MYERS DRUG, (Case No. 24-50146-

RLJ-11) is an affiliate of the Debtors. The Debtors would submit that Bankruptcy Rule 

1015 allows for the joint administration of these estates. The Debtors would further show 

that the majority of the creditors are the same in both cases and there is little or no potential 

for a conflict of interest. 

III.

The Debtors submit that granting their Motion For Joint Administration of its case 

with that of MP SOUTHPARK PHARMACY, LLC d/b/a MYERS DRUG for joint 

administration would be more convenient for all parties in interest and creditors of the two

estates. The Debtors would like to propose a joint Subchapter V Plan of Reorganization to 

the creditors of the two estates.

WHEREFORE, PREMISES CONSIDERED, MICAH G. PRATT and wife, 

KRYSTAN L. PRATT pray for an Order of the Court Approving their Motion For Joint 

Administration of their case with that of MP SOUTHPARK PHARMACY, LLC d/b/a 

MYERS DRUG, and asks for such other relief at law or equity to which it may show itself 

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Debtors’ Motion For Joint Administration

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justly entitled.

Respectfully Submitted, 

MULLIN HOARD & BROWN, L.L.P.

P.O. Box 2585

 Lubbock, Texas 79408-2585

Telephone: (806) 765-7491

Facsimile: (806) 765-0553

__/s/ David R. Langston______________

David R. Langston, SBN: 11923800

Attorneys for Debtors, MP Southpark 

Pharmacy, LLC d/b/a Myers Drug and 

Micah and Krystan Pratt

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CERTIFICATE OF SERVICE

This is to certify that a true and correct copy of the foregoing Motion was served 

via e-mail on this the 25th day of June, 2024 to the following listed parties in interest:

1. MP Southpark Pharmacy

Attn: Micah Pratt

1506 A. South Sunset

Littlefield, TX 79339

Debtor

2. Micah & Krystan Pratt

203 East 26th St.

Littlefield, Texas 79339

3. U.S. Trustee’s Office

1100 Commerce St., Room 9C60

Dallas, Texas 75242

4. All parties receiving ECF Notice in this case.

_/s/ David R. Langston_________

David R. Langston

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