Free Notice (Other) - District Court of Delaware - Delaware

Case 1 :04-cv-00619-GIVIS Document 7 Filed 11/22/2005 Page 1 of 3
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
In re: ) Chapter 11
)
SAMUELS JEWELERS, INC., )
) Bankr. Case No. 03-12399 (MFW)
Debtor. )
)
)
Samuels Jewelers, Inc., )
) Civil Case No. 04-619 (GMS)
Plaintiff, )
)
v. )
)
Michelle Shoop-Doddy, )
)
Defendant. )
NOTICE OF COMPLETION OF BRIEFING
In accordance with this Court’s procedures, Plaintiff, Samuels Jewelers, Inc. ("Plaintiff"),
by its attomeys, hereby notifies the Court that briefing on Plaintiffs Motion to (1) Withdraw the
Reference; (2) Disallow Priority Claim Status, and (3) Disallow Claim Filed by Michelle Shoop-
Doddy (Claim No. 162) (the "Motion") [Docket No. 1], with respect to disallowing the claim and
its status, is complete.
On June 28, 2004, Plaintiff tiled it’s Motion. On October 15, 2004, the Court entered an
Order Withdrawing the Reference as to Objection to Claim of Michelle Shoop-Doddy (Claim
No. 162) [Docket No. 5]. To date, Plaintiff has received no response from the Defendant on the
Motion. A status conference with respect to closing the related bankruptcy case will be held on
December 14, 2005 at 11:30 a.m. before The Honorable Mary F. Walrath. The Debtor would
like to resolve the Motion before it closes the bankruptcy case.

Case 1:04-cv—00619-G|\/IS Document 7 Filed 11/22/2005 Page 2 of 3
Pursuant to District Court Local Rule 7.1.2, the briefing related to the Motion has been
completed. Plaintiff respectfully requests the Court consider the Motion and disallow the claim
of Michelle Shoop-Doddy. Plaintiff is available for oral argument if the Court so desires.
Dated: November L74 2005
GREENBERG TRAURIG, LLP
Wéam E. Chipman, Jr. (DE No. 3818)
The Nemours Building
1007 North Orange Street, Suite 1200
Wilmington, DE 19801
(302) 661-7000
and
Michael L. Tuchin (CA Bar No. 150375)
Martin R. Barash (CA Bar No. 162314)
Klee, Tuchin, Bogdanoff & Stern LLP
2121 Avenue of the Stars, 33rd Floor
Los Angeles, CA 90067-5061
(310) 407-4000
Counsel to the Plaintiff
- 2 -

Case 1 :04-cv-00619-GIVIS Document 7 Filed 11/22/2005 Page 3 of 3
CERTIFICATE OF SERVICE
I, William E. Chipman, Jr, being duly swom according to law, deposes and says that I am
employed by Greenberg Traurig, LLP, which is counsel for the Plaintiff and that on the 22nd of
November 2005, I caused to be served (2) copies of the Notice of Completion 0fBriejing upon
the parties listed below as indicated.
Robert A. Hanna, Esq.
The Henger Law Firm
14350 Civic Drive #270
Victorville CA 92392
(counsel to Michelle Shoop-Doddy)
Wil . Chi . o. 3818)
- 3 -

Case 1:04-cv-00619-GMS

Document 7

Filed 11/22/2005

Page 1 of 3

Case 1:04-cv-00619-GMS

Document 7

Filed 11/22/2005

Page 2 of 3

Case 1:04-cv-00619-GMS

Document 7

Filed 11/22/2005

Page 3 of 3