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Trustee’s Notice of Abandonment 

Scott M. Seidel 

SEIDEL LAW FIRM 

6505 W. Park Blvd., Suite 306 

Plano, Texas 75093 

scott@scottseidel.com 

Counsel for the Chapter 7 Trustee 

IN THE UNITED STATES BANKRUPTCY COURT 

FOR THE NORTHERN DISTRICT OF TEXAS 

DALLAS DIVISION 

IN RE: 

MIP POLYFORM, INC. 

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Case No. 24-32351-sgj-7 

 DEBTOR 

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Chapter 7 

TRUSTEE’S NOTICE OF INTENT TO ABANDON 

A RESPONSE IS REQUIRED TO THIS NOTICE NO LATER THAN 

NOVEMBER 18, 2024, WHICH IS FOURTEEN (14) DAYS FROM THE DATE OF 

SERVICE HEREOF, OR THE RELIEF REQUESTED MAY BE DEEMED TO HAVE 

OCCURRED AND WAS UNOPPOSED. A RESPONSE MUST FILED WITH THE 

CLERK OF THE UNITED STATES BANKRUPTCY COURT, EARLE CABELL 

FEDERAL BUILDING, 1100 COMMERCE STREET, ROOM 1254, DALLAS, TEXAS 

75242-1496. 

 ANY RESPONSE MUST BE 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 TO (1) THE DEBTOR AND DEBTOR’S ATTORNEY; (2) THE 

OFFICE OF THE U.S. TRUSTEE; (3) ANY TRUSTEE AND THE TRUSTEE’S 

ATTORNEY; (4) THE MEMBERS OF ANY OFFICIAL COMMITTEE, OR THE 

ATTORNEY FOR ANY OFFICIAL COMMITTEE IF AN ATTORNEY HAS BEEN 

EMPLOYED; OR IF THERE IS NO COMMITTEE, THE TWENTY (20) LARGEST 

UNSECURED CREDITORS; (5) ANY PARTY REQUESTING NOTICE; (6) ANY 

PARTY NAMED ON A COURT-APPROVED ALTERNATIVE SERVICE LIST; (7) THE 

RESPONDING PARTIES; AND (8) ANY OTHER AFFECTED ENTITY. 

 

 IF NO HEARING ON SUCH NOTICE OR MOTION INITIATING A 

CONTESTED MATTER IS TIMELY REQUESTED, THE RELIEF REQUESTED 

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

ORDER GRANTING THE RELIEF SOUGHT. THE NOTICED ACTION WILL BE 

DEEMED TO HAVE OCCURRED WITH OR WITHOUT COURT ORDER. 

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Trustee’s Notice of Abandonment 

COMES NOW Scott M. Seidel, the Chapter 7 Trustee (the "Trustee") in the 

above-referenced case, and files his Trustee's Notice of Intent to Abandon (the "Notice") and 

would respectfully state as follows: 

1. On April 30, 2024, MIP Polyform, Inc. (the “Debtor”) filed a voluntary 

petition for relief under Chapter 7 under Title 11 of the United States Bankruptcy Code. 

Scott M. Seidel was appointed as Chapter 7 Trustee and continues to serve in that capacity. 

2. The has Debtor had scheduled machinery and equipment and molds used by 

the debtor in making of molds and other types of forms (the “machinery and or “equipment” 

or “Scheduled Assets”). The equipment was left at the debtor’s former leased premises at 

the time of filing. The trustee, his counsel and the debtor representative have photographed 

the equipment and reached out to several sources who might be interested. The debtor 

representative, Mr. Charles Farmer, testified that the equipment and forms are very specific 

to a unique type of manufacturing that would not be used by very many people nationwide as 

well as that the equipment was old and newer molds and equipment would be much more 

desirable to a purchaser. Despite repeated attempts by the trustee and his counsel, no offers 

of any kind were received. The potential auctioneer did not believe liquidation would be 

beneficial to creditors. The landlord has locked the debtor’s former premises and is owed 

funds. 

3. The Trustee is abandoning the machinery and molds in the normal process of 

administering the case in light of the costs, delay, and uncertainty concerning the liquidation and 

distribution of any proceeds concerning the machinery. The trustee abandons the machinery and 

molds only and NOT the funds on hand. 

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Trustee’s Notice of Abandonment 

4. The Trustee reserves the right to withdraw this Abandonment at his sole 

discretion at any time during the 14-day period including, but not limited to, November 18, 2024, 

and reserves all estate rights to the machinery until notice has run and the case is closed. 

 WHEREFORE, PREMISES CONSIDERED, unless a written response or 

objection to this Notice of Intent to Abandon is received by November 18, 2024, which is 

fourteen (14) days from the date of filing of this Notice, the Trustee will be deemed to have 

abandoned the Debtor’s Scheduled Assets without further notice or Order from this Court. The 

Trustee further requests such other and further relief as may be just. 

Respectfully submitted, 

/s/ Scott M. Seidel

 Scott M. Seidel, Esq. 

 State Bar No. 17999450 

 6505 W. Park Blvd., Suite 306

Plano, Texas 75093 

 Telephone: 214-234-2500 

 scott@scottseidel.com 

 Counsel for the Chapter 7 Trustee 

CERTIFICATE OF SERVICE 

I hereby certify that the foregoing notice was served upon the United States Trustee, 

counsel for the Debtor and the parties who receive electronic notification in this case and to the 

parties on the attached service list by ECF and/or by US first class mail, postage pre-paid, on this 

4th day of November 2024. 

 /s/ Scott M. Seidel

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