THE LANE LAW FIRM, PLLC

Robert C. Lane

State Bar No. 24046263

notifications@lanelaw.com

6200 Savoy, Suite 1150

Houston, Texas 77036

(713) 595-8200 Voice

(713) 595-8201 Facsimile

PROPOSED COUNSEL FOR DEBTOR

IN THE UNITED STATES BANKRUPTCY COURT

 FOR THE NORTHERN DISTRICT OF TEXAS

 DALLAS DIVISION

IN RE: §

FREDRICK LEE PRESS PLUMBING, LLC §

DEBTOR § BANKRUPTCY CASE NO. 23-32662

MOTION FOR AUTHORITY TO USE CASH COLLATERAL

NO HEARING WILL BE CONDUCTED ON THIS MOTION UNLESS A WRITTEN 

OBJECTION OR REQUEST FOR HEARING IS FILED WITH THE UNITED STATES 

BANKRUPTCY CLERK, 1100 COMMERCE STREET, ROOM 1254, DALLAS, TEXAS 

75242-1496, WITHIN TWENTY-ONE (21) DAYS FROM THE DATE OF THE FILING OF 

THIS MOTION, UNLESS THE COURT, SUA SPONTE, OR UPON TIMELY 

APPLICATION OF A PARTY IN INTEREEST, SHORTENS OR EXTENS THE TIME 

FOR FILING SUCH OBJECTION OR REQUEST FOR HEARING.

IF NO OBJECTION OR REQUEST FOR HEARING IS TIMELY FILED, THE MOTION 

SHALL BE DEEMED TO BE UNOPPOSED AND THE COURT MAY ENTER AN 

ORDER GRANTING THE RELIEF SOUGHT. THE COURT RESERVES THE RIGHT 

TO SET ANY MATTER FOR HEARING.

TO THE HONORABLE UNITED STATES BANKRUPTCY JUDGE:

COMES NOW, Fredrick Lee Press Plumbing, LLC (“Debtor”) and files this Motion for 

Authority to Use of Cash Collateral pursuant to 11 U.S.C. § 363. The Debtor presents this 

Application and respectfully represents the following:

1. On November 14, 2023 ("Petition Date"), the Debtor filed a voluntary petition 

for relief under Chapter 11 of Title 11 of the United States Code, 11 U.S.C. §§ 101-1532 

Case 23-32662-mvl11 Doc 6 Filed 11/14/23 Entered 11/14/23 14:08:15 Desc Main

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("Bankruptcy Code") and is now operating its business as a Debtor-In-Possession.

2. The Debtor continues to manage and operate its retail and commercial repair and 

service plumbing business as Debtor-In-Possession pursuant to §§1107 and 1108 of the 

Bankruptcy Code. 

3. A search in the Texas Secretary of State shows that allegedly secured positions are held 

by Fundation Group LLC (Factor), US Small Business Administration, Global Merchant Cash Inc, 

Newtek Small Business Finance, LLC, BizFund, Blue Ribbon, Fox Capital, Knightsbridge, Samson 

Funding, Samson Group and Swift Funding Source. (See Exhibit “B” for full list).

4. The loans are allegedly secured by a blanket lien on all accounts and property of 

the Debtors’ businesses, pursuant to the filed UCC liens that have been filed. At this early stage, 

it is unclear as to whether these agreements are secured and/or comply with Texas or other state 

usury laws, but for the purposes of this motion only, Debtor is acknowledging their UCC filings.

5. The Debtor depends on the use of cash collateral for contract services, payroll 

and general operating expenses. Revenue is generated through the Debtor’s retail and 

commercial repair and service plumbing business. 

6. It is critical to the operation of the Debtor’s business, and to its reorganization 

efforts, that it be permitted to pay these expenses using cash collateral. The Debtor produces 

revenue from its inspection business and would use such revenue to pay the budgeted expenses. 

Moreover, such revenue will be deposited by Debtor in its DIP operating account pending entry 

of an order allowing use of cash collateral or consent by lien holders. 

7. Attached as Exhibit A is a 14- and 30-day budget for the Debtor, showing 

projected income and expenses. The amounts listed are reasonable and good faith estimations 

of what the Debtor needs to spend each month to continue the operations of its business and

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reorganize. 

8. In addition to Exhibit A, the following Exhibit is also attached:

Exhibit B UCC Lien Search

9. Debtor requests authority to use the cash collateral for expenses set forth on 

Exhibit “A” and any other unforeseeable expenses that may arise and pose a threat to the 

Debtor’s continued operations. Specifically, the Debtor requests authority to use the cash 

collateral to pay up to 110% of each expense in Exhibit A, so long as the total of cash collateral 

spent during the month does not exceed by more than 5% of that month’s total in Exhibit A.

10. This “First Day Motion” is being filed alongside with the Voluntary Petition 

under the Court’s Standing Order on First Day Motions in Chapter 11 cases. 

WHEREFORE, PREMISES CONSIDERED, the Debtor requests this matter be 

set for hearing and that upon hearing, the Court will enter an Interim Order authorizing the 

Debtor’s use of the cash collateral in the amounts set forth in Exhibit “A” and for such other 

and further relief as the Debtor may show itself justly entitled.

Respectfully submitted,

THE LANE LAW FIRM, PLLC

/s/Robert C. Lane

Robert C. Lane

State Bar No. 24046263

notifications@lanelaw.com 

Joshua D. Gordon

State Bar No 24091592

Joshua.gordon@lanelaw.com 

6200 Savoy, Suite 1150

Houston, Texas 77036

(713) 595-8200 Voice

(713) 595-8201 Facsimile

PROPOSED COUNSEL FOR DEBTOR

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CERTIFICATE OF SERVICE

I hereby certify that a true and correct copy of the Debtor’s Motion for Authority to Use 

Cash Collateral was served upon the US Trustee and to the parties listed on the service list below 

and the attached mailing matrix either via electronic notice by the court’s ECF noticing system or 

by United States first class mail, postage prepaid, and by electronic mail as listed below on 

November 14, 2023:

Debtor:

Fredrick Lee Press Plumbing, LLC

9056 FM 1641 

Terrell, Texas 75160

US Trustee:

Office of the U.S. Trustee: 

1100 Commerce Street

Room 976

Dallas, TX 75242

Parties Requesting Notice

ustpregion06.da.ecf@usdoj.gov

Electronic Mail Notification:

underwriting@foxbusinessfunding.com

reconciliations@samsonfunding.com

info@blueribbonfunds.com

Reconciliations@blueribbonfunds.com

customerservice@approvalandreconciliation.com – Samson Group

subs@knightsbridgefunding.com

bankruptcy@swiftcapital.com

lrocklin@npmlaw.com – Blue Ribbon Attorney

mike@zahavassetmgmt.com

collections@evlawpllc.com – Attorney for Swift Funding Source Inc.

ari@bblawpllc.com – Attorney for Samson MCA

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Document Page 4 of 7
info@wallfunding.com – Global Merchant Cash Inc

brian@bizfund.com

dawn.theiss@usdoj.gov

lfadini@newtekone.com

info@fundation.com

/s/ Robert “Chip” Lane

Robert “Chip” Lane

Case 23-32662-mvl11 Doc 6 Filed 11/14/23 Entered 11/14/23 14:08:15 Desc Main

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 Label Matrix for local noticing Fredrick Lee Press Plumbing, LLC U.S. Attorney 

 0539-3 9056 FM 1641 1100 Commerce, 3rd Floor 

 Case 23-32662-mvl11 Terrell, TX 75160-7366 Dallas, TX 75242-1074 

 Northern District of Texas 

 Dallas 

 Tue Nov 14 13:44:20 CST 2023 

 U.S. Attorney General 1100 Commerce Street Berkovitch & Bouskila, PLLC 

 Department of Justice Room 1254 1545 US 202 Suite 101 

 Washington, DC 20001 Dallas, TX 75242-1305 Pomona, NY 10970-2951 

 

 Bizfund LLC Blue Ribbon Funding Brandy Press-Smith 

 2371 Mcdonald Ave 2nd Fl 1317 Edgewater Drive Suite 1845 9056 FM 1641 

 Brooklyn, NY 11223-4738 Orlando, FL 32804-6350 Terrell, TX 75160-7366 

 Ershowsky Verstandig (p)FORD MOTOR CREDIT COMPANY Fox Capital Group, Inc. 

 290 Central Avenue Suite 109 P O BOX 62180 803 S 21st Avenue 

 Lawrence, NY 11559-8507 COLORADO SPRINGS CO 80962-2180 Hollywood, FL 33020-6962 

 Fredrick Lee Press Fundation Group LLC Global Merchant Cash Inc. 

 9056 FM 1641 11501 Sunset Hills Road Suite 100 640 Beavers Street 415 

 Terrell, TX 75160-7366 Reston, VA 20190-6700 New York, NY 10004 

 Knightsbridge Funding LLC Mercedes Benz Financial Nathaniel Smith 

 40 Wall Street Suite 2903 PO Box 685 9056 FM 1641 

 New York, NY 10005-1304 Roanoke, TX 76262-0685 Terrell, TX 75160-7366 

 Neubert, Pepe & Monteith, P.C. Newtek Small Business Finance Samson Funding 

 195 Church Street, 13th Floor 1981 Marcus Ave Suite 130 17 State Street, 6th Floor Suite 630 

 New Haven, CT 06510-4011 New Hyde Park, NY 11042-1046 New York, NY 10004-1749 

 Samson Group Swift Funding Source Inc The Lane Law Firm 

 400 Rella Blvd Suite 165-101 2474 McDonald Ave 6200 Savoy Dr Ste 1150 

 Suffern, NY 10901-4241 Brooklyn, NY 11223-5233 Houston, TX 77036-3369 

 U.S. Small Business Administration United States Trustee Zahav Asset Management LLC 

 Loan Servicing Center 1100 Commerce Street 234 Cedarhurst Ave. Apt. 21B 

 2120 Riverfront Drive Suite 100 Room 976 Cedarhurst, NY 11516-1608 

 Little Rock, AR 72202-1794 Dallas, TX 75242-0996 

 Robert Lane 

 The Lane Law Firm 

 6200 Savoy, Suite 1150 

 Houston, TX 77036-3369 

Case 23-32662-mvl11 Doc 6 Filed 11/14/23 Entered 11/14/23 14:08:15 Desc Main

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 The preferred mailing address (p) above has been substituted for the following entity/entities as so specified 

 by said entity/entities in a Notice of Address filed pursuant to 11 U.S.C. 342(f) and Fed.R.Bank.P. 2002 (g)(4). 

 Ford Motor Credit Company LLC 

 c/o National Bankruptcy Service Center 

 PO Box 62180 

 Colorado Springs, CO 80962 

 The following recipients may be/have been bypassed for notice due to an undeliverable (u) or duplicate (d) address. 

 (d)Fredrick Lee Press Plumbing, LLC End of Label Matrix 

 9056 FM 1641 Mailable recipients 27 

 Terrell, TX 75160-7366 Bypassed recipients 1 

 Total 28 

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