Free Bankruptcy Appeal - District Court of Delaware - Delaware

Case 1:06-cv-00021-GMS

Document 1

Filed 01/11/2006

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IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE In re: U.S. WIRELESS CORPORATION, INC., WIRELESS LOCATION TECHNOLOGIES, INC., AND WIRELESS LOCATION SERVICES, INC., Debtors. ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) Chapter 11 Case No. 01-10262 through 01-10264 (PJW)

Jointly Administered

THE LIQUIDATING TRUST OF U.S. WIRELESS CORPORATION, INC., WIRELESS LOCATION TECHNOLOGIES, INC., AND WIRELESS LOCATION SERVICES, INC., Plaintiff, v. NEERAJ BHATNAGAR, Defendant.

Adv. Pro. No. 03-55654 (PJW)

NOTICE OF APPEAL Pursuant to 28 U.S.C. § 158(a) and Federal Rules of Bankruptcy Procedure 8001, defendant Neeraj Bhatnagar, by and through his undersigned counsel, hereby gives notice of appeal to the United States District Court for the District of Delaware from that portion of the Order and related Memorandum Opinion of the Bankruptcy Court dated November 23, 2005, copies of which are attached hereto, where the Court ruled that "[s]ince the Debtors never collected or withheld any money from Bhatnagar, no trust could have been created. The Property belonged to the Debtors and is, therefore, potentially recoverable."

Case 1:06-cv-00021-GMS

Document 1

Filed 01/11/2006

Page 2 of 2

The names of the parties to the Order and Memorandum Opinion appealed from and the names, addresses, and telephone numbers of their respective attorneys are as follows: Party Appellant: Neeraj Bhatnagar Attorneys: Frederick B. Rosner, Esquire (No. 3995) Jaspan Schlesinger Hoffman LLP 913 North Market Street, 12th Floor Wilmington, DE 19801 (302) 351-8000

Appellee: The Liquidating Trust of U.S. Wireless Corporation, Inc., Wireless Location Technologies, Inc., and Wireless Location Services, Inc.

Joanne B. Wills, Esquire Jennifer L. Scoliard, Esquire Klehr, Harrison, Harvey Branzburg & Ellers LLP 919 Market Street Wilmington, DE 19801 (302) 777-6500

Dated: December 2, 2005 JASPAN SCHLESINGER HOFFMAN LLP By: /s/ Frederick B. Rosner Frederick B. Rosner (No. 3995) 913 North Market Street, 12th Floor Wilmington, DE 19801 Telephone: (302) 351-8000 Facsimile: (302) 351-8010

Attorney for Appellant/Defendant, Neeraj Bhatnagar

#15781

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