IN THE UNITED STATES BANKRUPTCY COURT

FOR THE NORTHERN DISTRICT OF TEXAS

AMARILLO DIVISION

IN RE: § 

§ 

MCCLAIN FEED YARD, INC., et al.,1 § CASE NO. 23-20084-RLJ-7 

§ 

§ 

Debtors, § Jointly Administered. 

MOTION TO TRANSFER JOINTLY ADMINISTERED CASES 

* * * * * * * * *

Come now Meagan B. Goad (“Goad”) and Kinsey Moreland (“Moreland” and together 

with Goad, “Interested Parties”), by counsel, and hereby file their Motion to Transfer Jointly 

Administered Cases pursuant to 28 U.S.C. §1412. In support of this Motion, Interested Parties 

respectfully state as follows:

Jurisdiction

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

is a core proceeding as defined in 28 U.S.C. § 157(b). 

2. The statutory bases for the relief sought in this Motion are 11 U.S.C. §§ 105, 1408, 

and 1412, and Fed. R. Bankr. P. 1014. 

I. Facts

1. On April 28, 2023 (the “Petition Date”), McClain Feed Yard, Inc. (“MFY”), 

McClain Farms, Inc. (“MFI”), and 7M Cattle Feeders, Inc. (“7M” and collectively with MFY and 

MFI, “McClain Debtors”) filed their voluntary petitions for relief under chapter 7 of title 11 of the 

United States Code (the “Bankruptcy Code”).

1 The Debtors in these chapter 7 cases are: McClain Feed Yard, Inc. (Case No. 23-20084-RLJ), McClain Farms, 

Inc. (Case No. 23-20085-RLJ), and 7M Cattle Feeders, Inc. (Case No. 23-20086-RLJ)

Case 23-20084-rlj7 Doc 82 Filed 07/18/23 Entered 07/18/23 14:02:00 Desc Main

Document Page 1 of 64
2 

McClain Feed Yard, Inc. 

2. MFY was founded in 2009 and is a Texas corporation with its principal place of 

business located at 824 Mullins Lane, Benton, Kentucky 42025. The sole owner of MFY was Brian 

McClain. Brian McClain resided at 824 Mullins Lane, Benton, Kentucky 42025. 

3. MFY books and records are maintained in Benton, Kentucky with Meagan Goad 

and Angela Powell listed as custodians on the Statement of Financial Affairs. [Doc. 48] Meagan 

Goad and Angela Powell reside in Kentucky and maintained the books and records in Kentucky. 

4. MFY held a bank account at Mechanics Bank which is headquartered in California. 

The checks written out of that bank account were written at the Benton, Kentucky address. 

5. Secured Lenders recorded UCC liens against MFY in Texas and Kentucky. 

6. MFY held title to one property located in Texas and some equipment located 

thereon. Rabo Agrifinance, LLC (“Rabo”) was granted relief from stay to foreclose on its collateral 

and the real property and equipment are no longer property of the estate. 

7. MFY listed feed as its only other asset in its petition and schedules. 

8. All of MFY’s co-debtors have their principal places of business in Kentucky and 

are incorporated in Kentucky. 

9. All MFY invoices and checks were issued from Kentucky and used the Benton, 

Kentucky address. 

McClain Farms, Inc.

10. MFI was founded in 2009 and is a Kentucky corporation with its principal place of 

business located at 824 Mullins Lane, Benton, Kentucky 42025. The sole owner of MFI was Brian 

McClain. Brian McClain resided at 824 Mullins Lane, Benton, Kentucky 42025. 

Case 23-20084-rlj7 Doc 82 Filed 07/18/23 Entered 07/18/23 14:02:00 Desc Main

Document Page 2 of 64
3

11. MFI books and records are maintained in Benton, Kentucky with Meagan Goad 

and Angela Powell listed as custodians on the Statement of Financial Affairs. [Doc. 56, Case No. 

23-20085] Meagan Goad and Angela Powell reside in Kentucky and maintained the books and 

records in Kentucky.

12. MFI held a bank account at Mechanics Bank which is headquartered in California. 

The checks written out of that bank account were written at the Benton, Kentucky address. 

13. MFI held two bank accounts at Chase Bank which is based out of Arizona. The 

checks written out of that bank account were written at the Benton, Kentucky address.

14. MFI held a bank account at Community Financial Services Bank which is 

headquartered in Kentucky. The checks written out of that bank account were written at the 

Benton, Kentucky address. 

15. Secured Lenders recorded UCC liens against MFI in Texas and Kentucky. 

16. MFI owns no real property in Texas or Kentucky. 

17. MFI’s list of equipment reflects that it is located in Benton, Kentucky. Rabo was 

granted relief from stay to foreclose on its collateral, so the equipment is no longer property of the 

estate. 

18. MFI holds a lease on land located in Kentucky. 

19. All of MFI’s co-debtors have a principal place of business in Kentucky. 

20. All MFI checks and invoices were issued from Kentucky and listed the Benton, 

Kentucky address for MFI. 

21. Riley Livestock is based in Mayfield, Kentucky and holds a claim against MFI 

totaling approximately $69 million. 

Case 23-20084-rlj7 Doc 82 Filed 07/18/23 Entered 07/18/23 14:02:00 Desc Main

Document Page 3 of 64
4

22. MAP Enterprises, Inc. is based in Mayfield, Kentucky and holds a claim against 

MFI totaling approximately $9.1 million. 

23. Wildforest Cattle Company, LLC is based in Mayfield, Kentucky and holds a claim 

against MFI totaling approximately $5.4 million.

7M Cattle Feeders, Inc.

24. 7M was founded in 2019 and is a Kentucky corporation with its principal place of 

business located at 824 Mullins Lane, Benton, Kentucky 42025. The sole owner of 7M was Brian 

McClain. Brian McClain resided at 824 Mullins Lane, Benton, Kentucky 42025. 

25. 7M books and records are maintained in Benton, Kentucky with Meagan Goad and 

Angela Powell listed as custodians on the Statement of Financial Affairs. [Doc. 52, Case No. 23-

20086] Meagan Goad and Angela Powell reside in Kentucky and maintained the books and records 

in Kentucky.

26. 7M held a bank account at Mechanics Bank which is headquartered in California. 

The checks written out of that bank account were written at the Benton, Kentucky address. 

27. Secured Lenders recorded UCC liens against 7M in Texas and Kentucky. 

28. 7M held title to one property located in Texas and some equipment located thereon. 

Rabo was granted relief from stay to foreclose on its collateral and the real property and equipment 

are no longer property of the estate. 

29. 7M listed feed as its only other asset in its petition and schedules. 

30. All of 7M’s co-debtors have a principal place of business in Kentucky. 

31. All 7M invoices and checks were issued from Kentucky and listed Benton, 

Kentucky address for 7M. 

Case 23-20084-rlj7 Doc 82 Filed 07/18/23 Entered 07/18/23 14:02:00 Desc Main

Document Page 4 of 64
5

Facts in Common to All Debtors

32. Rabo was the McClain Debtors’ primary lender and is based out of Chesterfield, 

Missouri. 

33. Prior to the bankruptcy cases, Rabo declared defaults under the loan documents and 

on April 6, 2023, Rabo, through counsel, issued its Default Notice by mail delivery to all of the 

McClain Debtors and guarantors at the Benton, Kentucky address. See at true and correct copy of 

the Default Notice attached hereto as Exhibit “A.” 

34. Also in April 2023, Rabo entered into an Amended and Restated Forbearance 

Agreement with the McClain Debtors and guarantors. A requirement of the Forbearance 

Agreement was the appointment of CFO Solutions, LLC d/b/a Ampleo as the chief restructuring 

officer of the McClain Debtors by April 10, 2023. The designated individual by Rabo was Glenn 

Karlberg. See a true correct copy of the Amended and Restated Forbearance Agreement attached 

hereto as Exhibit “B.”

35. On April 25, 2023, after Mr. McClain’s passing, Rabo initiated its lawsuit against 

the McClain Debtors in the proper venue, the Western District of Kentucky. See, Case No. 23-CV55-BJB in the Western District of Kentucky, Paducah Division. See a true and correct copy of the 

Verified Complaint attached hereto as Exhibit “C.”

36. In its Verified Complaint, Rabo avers in paragraph 10, “[v]enue is proper in this 

Court pursuant to 28 U.S.C. §1391 because all Defendants reside or maintain place of business in 

this district and the collateral and personal property that is the subject matter of this Verified 

Complaint are located in this district.” See, Exhibit C, Para. 10. 

37. Rabo has blanket liens on McClain Debtors’ collateral. 

Case 23-20084-rlj7 Doc 82 Filed 07/18/23 Entered 07/18/23 14:02:00 Desc Main

Document Page 5 of 64
6 

38. Inexplicably, after averring that venue is proper in the Western District of Kentucky 

based upon the debtors’ “place of business” and location of “collateral and personal property,” 

Rabo’s appointed CRO initiated Chapter 7 proceedings in the Northern District of Texas. 

39. Glenn Karlberg, the McClain Debtors’ chief restructuring officer, is based in 

Arizona. 

40. On May 9, 2023, Rabo filed its Ex Parte Motion for Rule 2004 Order Authorizing 

the Issuance of Document Subpoenas to Various Third Parties (the “2004 Motion”). [Doc. 17] 

41. Rabo’s 2004 Motion lists eleven (11) persons or entities believed to have 

discoverable information relevant to the estate and affairs of the debtors. Of those eleven (11), 

only two (2) are based in Texas while eight (8) are based in Kentucky. One is based in California. 

As a result, nine (9) out of eleven (11) of the relevant witnesses and information are located beyond 

the subpoena power of this Court. 

42. The cattle were located in both Texas and Kentucky, among other locations. 

43. All of the litigation that was pending at the time the case was filed is pending 

resolution in Colorado (USDA Claims) or Kentucky, only. 

44. The Chapter 7 Trustee for the McClain Debtors asserts that “any substantial assets 

of this case will result from Chapter 5 claims and other litigation.” See, Doc. 54, Trustee’s 

Response to Rabo’s Motion for Relief from Automatic Stay.

45. The Chapter 5 claims will be controlled by Kentucky state law under Texas choice 

of law rules based upon “most significant contacts” test. 

46. The Section 341 meeting of creditors was conducted jointly for all three debtors on 

June 14, 2023 and was largely ineffectual based on lack of information. 

Case 23-20084-rlj7 Doc 82 Filed 07/18/23 Entered 07/18/23 14:02:00 Desc Main

Document Page 6 of 64
7 

II. Argument and Citation of Authorities

These bankruptcy cases should be transferred to the United States Bankruptcy Court for 

the Western District of Kentucky, Paducah Division. The McClain Debtors’ principal place of 

business was Benton, Kentucky with the domicile of only one of the debtors technically being in 

the Northern District of Texas solely based on place of incorporation. The witnesses, evidence, 

and books and records are primarily located in Benton, Kentucky. The alleged fraudulent acts took 

place in Benton, Kentucky. The Debtors literally complied with 28 U.S.C. §1408 but should not 

be allowed to forum shop where Rabo already averred in its Verified Complaint that the place of 

business and property are located in the Western District of Kentucky. This is particularly relevant 

in that the CRO for the McClain Debtors was selected and required by Rabo. 

A. Venue is Proper in the United States Bankruptcy Court for the Western District of 

Kentucky, Paducah Division. 

28 U.S.C. §1408 provides that “a case under title 11 may be commenced in the district 

court for the district in which the domicile, residence, principal place of business in the United 

States, or principal assets in the United States, of the person or entity that is the subject of such

case have been located.” Here, there is no dispute that the McClain Debtors’ principal place of 

business was in Benton, Kentucky. The Secretary of State websites for Kentucky and Texas 

indicate the same. The largest secured creditor of all three debtors likewise admitted as much in 

its Verified Complaint. The sole owner of the McClain Debtors was Brian McClain. Mr. McClain 

lived in Benton, Kentucky until his passing and his estate is being probated there. The “most 

important, consequential, or ‘influential’ place where a corporation or partnership does business is 

likely to be the place where its management decisions are made.” Matter of Peachtree Lane 

Associates, Ltd., 150 F.3d 788, 795 (7th Cir. 1998)(agreeing with the Fifth Circuit, C.I.R. v. 

Solomon, 506 U.S. 168, 174 (1993)). All of the McClain Debtors’ decisions and activities were 

Case 23-20084-rlj7 Doc 82 Filed 07/18/23 Entered 07/18/23 14:02:00 Desc Main

Document Page 7 of 64
8 

made in the Western District of Kentucky. All of the McClain Debtors have their principal places 

of business in the Western District of Kentucky. 

The McClain Debtors’ principal assets are cash, cash equivalents, accounts receivable, 

chapter 5 causes of action and related litigation. The nerve center for these debtors has always been 

in Benton, Kentucky. Debtors’ land and equipment assets are fully encumbered and worth a 

fraction of recoveries likely to be sought in this case. Debtors’ accounts receivable, checks, 

records, and bank accounts are all handled in Benton, Kentucky. The cattle were located in 

different locations including, but not limited to, Kentucky and Texas. The only tie to Texas for 

venue in Texas is “domicile” of MFY solely due to its incorporation in Texas. MFI and 7M could 

only file in Texas as “related to” entities. MFI boasts the largest summary of liabilities at $175 

million with 7M holding the largest summary of assets at $1.1 million. 

B. The Bankruptcy Cases Should be Transferred Pursuant to 28 U.S.C. §1412. 

“A district court may transfer a case or proceeding under title 11 to a district court for 

another district, in the interest of justice or for the convenience of the parties.” 28 U.S.C. §1412. 

The basis for venue in Texas is that MFY is incorporated in Texas. Although MFY is still 

technically a Texas corporation, it has no ongoing operation in Texas and no offices there. While 

it may exist in Texas, it does so in name only. Debtors’ principal lived in Kentucky and Debtors’ 

books and records were maintained in Kentucky. See, e.g. In re Custom Builders of Steamboat, 

Inc., 349 B.R. 39, 43 (Bankr.D.Idaho 2005)(holding venue proper in Idaho even though debtor 

was still technically a Colorado corporation but had no ongoing operations or offices there) See 

also, In re Weber, 118 B.R. 441, 444 (Bankr. E.D.Va. 1990)(holding venue for Chapter 7 

liquidation of corporate debtor proper in New York where accountant, books, and records were 

located even though assets of nominal importance to the liquidation of the estate were located in 

Case 23-20084-rlj7 Doc 82 Filed 07/18/23 Entered 07/18/23 14:02:00 Desc Main

Document Page 8 of 64
9 

Virginia). Here, it is clear that only assets of nominal importance to the liquidation of the McClain 

Debtors were located in the Northern District of Texas. 

1. Interest of justice standard. 

“The standard for transfer in the interest of justice is flexible, and relevant factors include 

the efficient administration of the bankruptcy estate, judicial economy, timeliness, and fairness. In

re BDRC Lofts, Ltd., 12-11559-CAG, 2013 WL 395129, at *2 (Bankr. W.D. Tex. Jan. 31, 2013). 

“The interest of justice prong is a broad and flexible standard that is applied based on the facts and 

circumstances of each case. In evaluating the interest of justice, the court must consider what will 

promote the efficient administration of the estate, judicial economy, timeliness, and fairness.” In 

re Enron Corp., 274 B.R. 327, 349 (Bankr. S.D.N.Y. 2002). These bankruptcy cases should be 

transferred in the interest of justice and to promote the integrity of the bankruptcy court system. 

a. Efficient Administration of the Estate. 

“[T]he factor given the most weight is the promotion of the economic and efficient 

administration of the estate.” In re Condor Expl., LLC, 294 B.R. 370, 378 (Bankr.D.Colo. 2003). 

Given the proximity of the McClain Debtors’ books and records to the Western District of 

Kentucky, Paducah Division, it is more efficient to administer and liquidate the estate there. The 

primary witnesses, largest unsecured creditors, Debtors’ principal places of business, and books 

and records are primarily located in the Western District of Kentucky. Nine of the eleven already 

identified parties with Rule 2004 information are beyond the subpoena power of this Court while 

eight out of eleven are within the subpoena power of the Western District of Kentucky. Although 

a trustee has been appointed over the McClain Debtors, very little has otherwise occurred in the 

administration of these bankruptcy cases. This factor tips in favor of a transfer to the Western 

District of Kentucky. 

Case 23-20084-rlj7 Doc 82 Filed 07/18/23 Entered 07/18/23 14:02:00 Desc Main

Document Page 9 of 64
10

b. Judicial Economy.

These bankruptcy cases have only been pending for approximately two and half months 

with the largely unproductive meeting of creditors having only recently taken place on June 14, 

2023. The Interested Parties point out that the likely reason for the largely unproductive 341 

hearing was due to the information necessary from witnesses and parties located in the Western 

District of Kentucky. There is not a significant learning curve for the bankruptcy court in the 

Western District of Kentucky especially in light of the number of cattle cases the Paducah division 

sees. The panel Chapter 7 trustee, Mark Little, is able and adept to handle cattle cases of this type. 

Mr. Little has served as a Chapter 7 trustee in the Paducah division for over ten (10) years and has 

handled a wide variety of cases including large Chapter 11 cases that are converted to Chapter 7. 

This factor also tips in favor of the Western District of Kentucky, Paducah Division for venue. 

c. Timeliness.

“If a petition is filed in the proper district, the court, on the timely motion of a party in 

interest or on its own motion, and after hearing on notice to the petitioners, the United States 

trustee, and other entities as directed by the court may transfer the case to any other district if the 

court determines that the transfer is in the interest of justice or for the convenience of the parties.” 

Fed. R. Bankr. P. 1014. These bankruptcy cases have only been pending for eighty-one (81) days. 

The skeletal petitions were filed on April 28, 2023 with amended skeletal petitions filed on May 

4, 2023. The schedules and statements of financial affairs for the McClain Debtors weren’t filed 

until June 7, 2023. The only substantive decision altering party rights was an agreed order on 

Rabo’s Motion for Relief from Stay on June 23, 2023. The Interested Parties submit that this 

motion is timely. 

Case 23-20084-rlj7 Doc 82 Filed 07/18/23 Entered 07/18/23 14:02:00 Desc Main

Document Page 10 of 64
11

d. Fairness. 

The Rabo appointed CRO selected the Northern District of Texas as the home court for 

these bankruptcy cases despite the thin nexus between the McClain Debtors and Texas. Given 

Rabo’s position in the Verified Complaint filed in Kentucky, the utilization of one debtor’s state 

of incorporation solely as a basis for venue of these bankruptcy cases gives the appearance of 

forum shopping by the Debtors’ largest secured lender. Although this factor would appear to tip 

in the McClain Debtors’ favor, the Court should look to the totality of the circumstances and 

representations that have been made by the parties. 

The facts preceding these bankruptcy cases support the conclusion that the Commonwealth 

of Kentucky has a strong interest in having the controversies decided within its borders, by those 

familiar with its laws. Much has already been written about these debtors with salacious detail 

regarding what has been called a “massive fraud” emanating out of Kentucky. The three largest 

unsecured USDA claimants totaling approximately $84 million are Kentucky businesses: MAP 

Enterprises, Inc., Riley Livestock, and Wildforest Cattle Company, LLC. The media outlets have 

described this as the second largest cattle ponzi scheme in history emanating from Benton, 

Kentucky. Kentucky law will govern the Chapter 5 causes of action so the Kentucky courts should 

apply and interpret its own laws. 

2. Convenience of parties. 

Six (6) factors are endorsed for consideration on a motion to transfer venue under the 

heading of convenience of the parties: (1) the proximity of the creditors of every kind to the Court; 

(2) the proximity of the debtor to the Court; (3) the proximity of the witnesses necessary to the 

administration of the estate; (4) the location of the assets; (5) the economic administration of the 

Case 23-20084-rlj7 Doc 82 Filed 07/18/23 Entered 07/18/23 14:02:00 Desc Main

Document Page 11 of 64
12

estate; and (6) the necessity for ancillary administration. See, Matter of Cmmw. Oil Refining Co., 

Inc., 596 F.2d 1239, 1247 (5th Cir. 1979). 

a. Proximity of Creditors

The largest unsecured USDA claimant creditors are located in the Western District of 

Kentucky holding approximately $84 million of the unsecured debt. Rabo is the largest secured 

creditor and is located in Missouri. The distance from Chesterfield, Missouri to Paducah, 

Kentucky is 196 miles or approximately a three-hour drive. By contrast, the distance from 

Chesterfield, Missouri to Amarillo, Texas is 782 miles or an eleven hour drive. It is clear that the 

creditors are likewise closer to the Western District of Kentucky Bankruptcy Court located in 

Paducah, Kentucky where this case should be transferred. The CRO was likewise aware that he 

was accepting a position in the Western District of Kentucky. 

b. Proximity of Debtor

The McClain Debtors all had a principal place of business in Benton, Kentucky where the 

owner of all three debtors resided until his death in April 2023. The Debtors’ books and records 

are maintained in Benton, Kentucky. The CRO is based in Arizona, not Texas. As such, the 

proximity of Debtor and its books and records weighs in favor of venue in the Western District of 

Kentucky. When Rabo first required the appointment of the CRO, it knew and averred that the 

Debtors were located in Benton, Kentucky. This factor weighs in favor of the Western District of 

Kentucky, Paducah Division. 

c. Proximity of Witnesses 

Rabo issued eleven Rule 2004 subpoenas to the witnesses it believed to have documents 

and information related to Debtors’ estates. Eight (8) of the eleven (11) reside in Kentucky. One 

has a principal place of business in California with only two (2) witnesses located in Texas. This 

Case 23-20084-rlj7 Doc 82 Filed 07/18/23 Entered 07/18/23 14:02:00 Desc Main

Document Page 12 of 64
13

factor weighs in favor of venue in Kentucky. “[T]he concern is with the corporation’s employees 

who must appear in court...” In re Pope Vineyards, 90 B.R. 252, 257 (Bankr.S.D.Tex. 1988). 

Here, in the very early stages of the bankruptcy cases, the participating creditor has already 

determined that eight of the eleven necessary witnesses are located in the Western District of 

Kentucky. This factor weighs in favor of transferring venue to the Western District of Kentucky. 

d. Location of Assets

The Chapter 7 Trustee in this case has averred that the likely primary source of recovery 

will be Chapter 5 causes of action yet to be identified. In addition, Rabo has already been granted 

relief from stay by agreed order to exercise its rights to debtors’ tangible assets upon which it held 

liens. The remaining items relevant to claims and causes of action are located in Benton, Kentucky 

and those items serve to be the most valuable pieces for the administration of these estates. 

e. Economic Administration of the Estate

“The bankruptcy court correctly concluded that the most important consideration is 

whether the requested transfer would promote the economic and efficient administration of the 

estate.” Matter of Cmmw. Oil Refining Co., Inc., 596 F.2d 1239, 1247 (5th Cir. 1979). Given the 

nerve center of the McClain Debtors as having always been in Benton, Kentucky, the relevant 

witnesses and documents are predominantly located in the Western District of Kentucky. The 

alleged acts of fraud occurred in Benton, Kentucky rendering it more likely than not that Kentucky 

law would be applied. Although this Bankruptcy Court is certainly able to interpret and apply 

Kentucky law, there are many other factors as outlined herein that warrant the transfer of venue to 

the Western District of Kentucky. 

Case 23-20084-rlj7 Doc 82 Filed 07/18/23 Entered 07/18/23 14:02:00 Desc Main

Document Page 13 of 64
14

f. Necessity for ancillary administration

As stated hereinabove, there are either none or very nominal value tangible assets 

remaining to administer in Texas. The bulk of what is necessary for the administration of these 

bankruptcy estates is located in Kentucky and beyond the subpoena power of this Court. It is more 

effective to transfer these bankruptcy cases to the Western District of Kentucky, Paducah Division 

for a Chapter 7 trustee to pursue the Chapter 5 causes of action where the Debtors’ books and 

records are located. 

WHEREFORE, the Interested Parties respectfully request that this Court transfer these

bankruptcy cases to the United States Bankruptcy Court for the Western District of Kentucky, 

Paducah Division. 

Respectfully submitted,

Boerner, Dennis & Franklin, PLLC

 Attorneys at Law

P.O. Box 1738 

 Lubbock, Texas 79408-1738 

 (806) 763-0044 

 (806) 763-2084 (fax) 

 Email: bfranklin@bdflawfirm.com 

 Email: cpatterson@bdflawfirm.com 

Email: ohutchin@bdflawfirm.com 

 /S/ William A. Franklin 

 _______________________________________ 

 William A. Franklin

State Bar No. 24007200 

Chandler Patterson

 State Bar No. 24121293 

 Orion Hutchin 

 State Bar No. 24122288 

ATTORNEYS FOR MEAGAN GOAD AND 

KINSEY MORELAND

Case 23-20084-rlj7 Doc 82 Filed 07/18/23 Entered 07/18/23 14:02:00 Desc Main

Document Page 14 of 64
15

Certificate of Conference

In accordance with L.B.R. 7007-1, Counsel for the Interested Parties contacted the 

respective counsels associated with this case and the Motion is opposed. 

/s/ William A. Franklin

WILLIAM A. FRANKLIN

Certificate of Service

I hereby certify that on July 18, 2023, a true and correct copy of the above and foregoing 

instrument has been served upon all parties receiving electronic notice via the Court’s CM/ECF 

system as well as those parties listed in the Matrix. 

/s/ William A. Franklin

WILLIAM A. FRANKLIN

Case 23-20084-rlj7 Doc 82 Filed 07/18/23 Entered 07/18/23 14:02:00 Desc Main

Document Page 15 of 64
Case 23-20084-rlj7 Doc 82 Filed 07/18/23 Entered 07/18/23 14:02:00 Desc Main

Document Page 16 of 64
Case 23-20084-rlj7 Doc 82 Filed 07/18/23 Entered 07/18/23 14:02:00 Desc Main

Document Page 17 of 64
Case 23-20084-rlj7 Doc 82 Filed 07/18/23 Entered 07/18/23 14:02:00 Desc Main

Document Page 18 of 64
Case 23-20084-rlj7 Doc 82 Filed 07/18/23 Entered 07/18/23 14:02:00 Desc Main

Document Page 19 of 64
Case 23-20084-rlj7 Doc 82 Filed 07/18/23 Entered 07/18/23 14:02:00 Desc Main

Document Page 20 of 64
Case 23-20084-rlj7 Doc 82 Filed 07/18/23 Entered 07/18/23 14:02:00 Desc Main

Document Page 21 of 64
Case 23-20084-rlj7 Doc 82 Filed 07/18/23 Entered 07/18/23 14:02:00 Desc Main

Document Page 22 of 64
Case 23-20084-rlj7 Doc 82 Filed 07/18/23 Entered 07/18/23 14:02:00 Desc Main

Document Page 23 of 64
Case 23-20084-rlj7 Doc 82 Filed 07/18/23 Entered 07/18/23 14:02:00 Desc Main

Document Page 24 of 64
Case 23-20084-rlj7 Doc 82 Filed 07/18/23 Entered 07/18/23 14:02:00 Desc Main

Document Page 25 of 64
Case 23-20084-rlj7 Doc 82 Filed 07/18/23 Entered 07/18/23 14:02:00 Desc Main

Document Page 26 of 64
Case 23-20084-rlj7 Doc 82 Filed 07/18/23 Entered 07/18/23 14:02:00 Desc Main

Document Page 27 of 64
Case 23-20084-rlj7 Doc 82 Filed 07/18/23 Entered 07/18/23 14:02:00 Desc Main

Document Page 28 of 64
Case 23-20084-rlj7 Doc 82 Filed 07/18/23 Entered 07/18/23 14:02:00 Desc Main

Document Page 29 of 64
Case 23-20084-rlj7 Doc 82 Filed 07/18/23 Entered 07/18/23 14:02:00 Desc Main

Document Page 30 of 64
Case 23-20084-rlj7 Doc 82 Filed 07/18/23 Entered 07/18/23 14:02:00 Desc Main

Document Page 31 of 64
Case 23-20084-rlj7 Doc 82 Filed 07/18/23 Entered 07/18/23 14:02:00 Desc Main

Document Page 32 of 64
Case 23-20084-rlj7 Doc 82 Filed 07/18/23 Entered 07/18/23 14:02:00 Desc Main

Document Page 33 of 64
Case 23-20084-rlj7 Doc 82 Filed 07/18/23 Entered 07/18/23 14:02:00 Desc Main

Document Page 34 of 64
Case 23-20084-rlj7 Doc 82 Filed 07/18/23 Entered 07/18/23 14:02:00 Desc Main

Document Page 35 of 64
Case 23-20084-rlj7 Doc 82 Filed 07/18/23 Entered 07/18/23 14:02:00 Desc Main

Document Page 36 of 64
Case 23-20084-rlj7 Doc 82 Filed 07/18/23 Entered 07/18/23 14:02:00 Desc Main

Document Page 37 of 64
Case 23-20084-rlj7 Doc 82 Filed 07/18/23 Entered 07/18/23 14:02:00 Desc Main

Document Page 38 of 64
Case 23-20084-rlj7 Doc 82 Filed 07/18/23 Entered 07/18/23 14:02:00 Desc Main

Document Page 39 of 64
Case 23-20084-rlj7 Doc 82 Filed 07/18/23 Entered 07/18/23 14:02:00 Desc Main

Document Page 40 of 64
Case 23-20084-rlj7 Doc 82 Filed 07/18/23 Entered 07/18/23 14:02:00 Desc Main

Document Page 41 of 64
Case 23-20084-rlj7 Doc 82 Filed 07/18/23 Entered 07/18/23 14:02:00 Desc Main

Document Page 42 of 64
Case 23-20084-rlj7 Doc 82 Filed 07/18/23 Entered 07/18/23 14:02:00 Desc Main

Document Page 43 of 64
Case 23-20084-rlj7 Doc 82 Filed 07/18/23 Entered 07/18/23 14:02:00 Desc Main

Document Page 44 of 64
Case 23-20084-rlj7 Doc 82 Filed 07/18/23 Entered 07/18/23 14:02:00 Desc Main

Document Page 45 of 64
Case 23-20084-rlj7 Doc 82 Filed 07/18/23 Entered 07/18/23 14:02:00 Desc Main

Document Page 46 of 64
Case 23-20084-rlj7 Doc 82 Filed 07/18/23 Entered 07/18/23 14:02:00 Desc Main

Document Page 47 of 64
Case 23-20084-rlj7 Doc 82 Filed 07/18/23 Entered 07/18/23 14:02:00 Desc Main

Document Page 48 of 64
Case 23-20084-rlj7 Doc 82 Filed 07/18/23 Entered 07/18/23 14:02:00 Desc Main

Document Page 49 of 64
Case 23-20084-rlj7 Doc 82 Filed 07/18/23 Entered 07/18/23 14:02:00 Desc Main

Document Page 50 of 64
Case 23-20084-rlj7 Doc 82 Filed 07/18/23 Entered 07/18/23 14:02:00 Desc Main

Document Page 51 of 64
Case 23-20084-rlj7 Doc 82 Filed 07/18/23 Entered 07/18/23 14:02:00 Desc Main

Document Page 52 of 64
Case 23-20084-rlj7 Doc 82 Filed 07/18/23 Entered 07/18/23 14:02:00 Desc Main

Document Page 53 of 64
Case 23-20084-rlj7 Doc 82 Filed 07/18/23 Entered 07/18/23 14:02:00 Desc Main

Document Page 54 of 64
Case 23-20084-rlj7 Doc 82 Filed 07/18/23 Entered 07/18/23 14:02:00 Desc Main

Document Page 55 of 64
Case 23-20084-rlj7 Doc 82 Filed 07/18/23 Entered 07/18/23 14:02:00 Desc Main

Document Page 56 of 64
Case 23-20084-rlj7 Doc 82 Filed 07/18/23 Entered 07/18/23 14:02:00 Desc Main

Document Page 57 of 64
Case 23-20084-rlj7 Doc 82 Filed 07/18/23 Entered 07/18/23 14:02:00 Desc Main

Document Page 58 of 64
Case 23-20084-rlj7 Doc 82 Filed 07/18/23 Entered 07/18/23 14:02:00 Desc Main

Document Page 59 of 64
Case 23-20084-rlj7 Doc 82 Filed 07/18/23 Entered 07/18/23 14:02:00 Desc Main

Document Page 60 of 64
Case 23-20084-rlj7 Doc 82 Filed 07/18/23 Entered 07/18/23 14:02:00 Desc Main

Document Page 61 of 64
Case 23-20084-rlj7 Doc 82 Filed 07/18/23 Entered 07/18/23 14:02:00 Desc Main

Document Page 62 of 64
Case 23-20084-rlj7 Doc 82 Filed 07/18/23 Entered 07/18/23 14:02:00 Desc Main

Document Page 63 of 64
Case 23-20084-rlj7 Doc 82 Filed 07/18/23 Entered 07/18/23 14:02:00 Desc Main

Document Page 64 of 64