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 APPROVAL OF POST-PETITION MONTHLY RETAINER PAYMENTS

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:

Fredrick Lee Press Plumbing, LLC (the “Debtor”), files this Motion for Approval of PostPetition Monthly Retainer Payments and establishing procedures for these post-petition monthly retainer 

deposits. In support thereof, the Debtor respectfully represent as follows:

I. Jurisdiction, Venue and Background

1. This Court has jurisdiction to consider the motion pursuant to 28 U.S.C. § 1334.

This is a core proceeding pursuant to 28 U.S.C. § 157(b)(2). Venue is proper before this Court pursuant

to 28 U.S.C. §§ 1408 and 1409.

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2. The statutory predicates for the relief requested herein are Sections 327 and 328 of

the Bankruptcy Code, Rule 2014 of the Federal Rules of Bankruptcy Procedure ("Bankruptcy Rules")

and Local Rule 2014 and 2016 of the Local Court Rules of the United States Bankruptcy Court for

the Northern District of Texas.

Background

3. 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 ("Bankruptcy

Code").

4. The Debtor continues to manage and operate its home and commercial service and 

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

Code. No creditors' committee has been appointed in this case by the United States Trustee.

5. By this Motion, Debtor respectfully requests the entry of an order, pursuant to Sections 

105(a) and 331 of the Bankruptcy Code and Bankruptcy Rules 2014 and 2016, establishing procedures 

for post-petition payments of professionals and deposits of post-petition monthly payments into the firms 

IOLTA trust account. These funds can only be applied for through and approved by the Court.

6. Debtor has already sought to engage a professional in this case in the capacity of 

Debtor’s Counsel, The Lane Law Firm, PLLC (Docket No. 10), seeking approval, under Section 327 of 

the Bankruptcy Code, to engage the firm to assist the Debtor.

7. The Debtor requests that the Court allow it to deposit $5,000.00 per month into The 

Lane Law Firm, PLLC’s IOLTA Trust Account until this case is administratively closed, for future postpetition legal fees of Debtor’s counsel and an additional amount of $1,500.00 per month to the 

Subchapter V Trustee into their Trust Account, both of which would be subject to Court approval through 

fee applications. The funds for The Lane Law firm, PLLC would be deposited for its future post-petition 

legal fees into its Trust Account and would be subject to Court approval. The future post-petition legal 

fees for the SubChapter V Trustee shall be directly deposited into their Trust Account and would be 

Case 23-32662-mvl11 Doc 11 Filed 11/14/23 Entered 11/14/23 14:43:36 Desc Main

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subject to further Court approval.

8. Debtor is requesting this motion for the Court to approve the monthly post-petition 

deposits pursuant to the terms of the Retainer Agreement. These monthly deposits do not in anyway put 

a financial strain on the current operations of the business. This motion is to help minimize impact of 

any temporary or final fee applications filed in this case so that Debtor has these funds already set aside 

in the firms IOLTA Trust account to pay these fees and expenses upon the entry of a Court order. These 

funds would still be subject to Court approval as stated in the Application to Employ (Docket No. 8) 

filed in this case.

PRAYER

WHEREFORE, Debtor hereby requests that this Court enter an order that allows the Debtor to 

deposit post-petition monthly payments into The Lane Law Firm, PLLC’s and the SubChapter V Trustee’s 

IOLTA Trust Accounts 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 Motion for Approval of Post-Petition Monthly 

Deposits was served to the parties listed below and to the parties on the attached mailing matrix either via 

e-mail, electronic notice by the court’s ECF noticing system, or by first-class mail pre-paid postage 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

 /s/Robert C. Lane

Robert C. Lane

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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 

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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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