Free Status Report - District Court of Delaware - Delaware

Case 1:04-cv-00433-SLR Document 12 Filed 06/30/2005 Page 1 of 3
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
In re: Case N0. 01-11657 (PJW)
CARIBBEAN PETROLEUM LP, et al.], CHAPTER 11
(J ointly Administered)
A Debtors.
HERNAN SERRANO, TRUSTEE OF THE Case No. 04-433 (SLR)
CARIBBEAN PETROLEUM CREDITORS’
TRUST, AND ON BEHALF OF THE ESTATES
OF THE ABOVE-CAPTIONED DEBTORS,
CARIBBEAN PETROLEUM, ET AL., AS
AUTHORIZED REPRESENTATIVE,
Plaintiff,
v.
U CAMIONEROS COOPERATIVA DE
TRANSPORTE DE CARGA; COOP
CAMIONEROS TRANSPORTE,
Defendants.
STATUS REPORT
Shortly before the last Status Conference held in the above-referenced matter on May 13,
2005, Plaintiff’s counsel was contacted by Kathleen J. Campbell of Campbell & Levine, LLC,
who stated that she may be taking over representation of the Defendant as local counsel at the
request of counsel of record, Irving K. Hemandez Valls.
Ms. Campbell represented that she would most likely be seeking relief from counsel of
record’s failure to respond to discovery and Plaintiff’s Motion for Partial Summary Judgment As
I The debtors are the following entities: Caribbean Petroleum, LP; Caribbean Oil LP; Caribbean
Petroleum Refining LP; Gulf Petroleum (Puerto Rico) Corporation and Caribbean Petroleum Corporation.
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Case 1:04-cv-00433-SLR Document 12 Filed 06/30/2005 Page 2 of 3
To The Preference Transfers And As To Defendant’s Affirmative Defenses based upon alleged
mental and physical disabilities suffered by counsel of record. _
On or about May 31, 2005, Plaintiff’s counsel contacted Ms. Campbell who advised that
she was not sure whether she would be undertaking the representation of the Defendant in this
matter, but would advise Plaintiff’s counsel with finality by June 15, 2005.
By way of an email dated June 20, 2005, Ms. Campbell advised Plaintiff’s counsel that
she would not be sewing as local counsel in the within litigation. ‘
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Case 1:04-cv-00433-SLR Document 12 Fi|ed_O6/30/2005 Page 3 of 3
On March 4, 2005, Plaintiff filed a Notice of Completion of Briefing With Respect to
Plaintiff’s Motion for Partial Summary Judgment As To The Preference Transfers And As To E
Defendant’s Affirmative Defenses. Plaintiff is awaiting the Court’s decision as to that motion.
Dated: June B, 2005 PACHULSKI, STANG, ZIEHL, YOUNG, JONES
& WEINTRAUB P.C.
Laura Davis Jones (DE Bar No. 2436)
Bruce Grohsgal (DE Bar No. 3583)
P.O. Box 8705
919 North Market Street, 16th Floor
Wilmington, DE 19899 (Courier 19801)
Telephone: (302) 652-4100
Facsimile: (302) 652-4400
— and —
Steven J. Kahn (CA Bar No. 76933)
10100 Santa Monica Blvd., 11th Floor
Los Angeles, California 90067-4100
Telephone: (310) 277-6910
Facsimile: (310) 201-0760
Attomeys for Plaintiff
Heman Serrano, Trustee of the Caribbean
Petroleum Creditors’ Trust
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