Second Stipulation And Agreed Order Regarding Extension Of

Summary

A Second Stipulation and Agreed Order Regarding Extension of Time to Respond to Darrick and Emily Gust's Motion for Relief from Stay, in In re Panthera Enterprises, LLC, Case No. 19-00787, Chapter 11, made as of June 17, 2020 between Panthera Enterprises, LLC and Darrick and Emily Gust. It recites that Darrick and Emily Gust filed the Motion for Relief from the Automatic Stay to Pursue Insurance with Combined Request for Allowance of Administrative Expense Claim on May 28, 2020, and that the Parties have been discussing a potential resolution of the Motion. It states that the Parties have agreed to extend the response date to July 1, 2020, subject to the approval of the Court. It bears /s/ signatures for John J. Richardson, Counsel for Debtor, and Spencer D. Elliot, Counsel for Movants.

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IN THE UNITED STATES BANKRUPTCY COURT
FOR THE NORTHERN DISTRICT OF WEST VIRGINIA

In re:

PANTHERA ENTERPRISES, LLC,

Case No. 19-00787

Chapter 11

Debtor.

SECOND STIPULATION AND AGREED ORDER REGARDING EXTENSION OF
TIME TO RESPOND TO DARRICK AND EMILY GUST’S MOTION FOR RELIEF
FROM STAY

This Stipulation and Agreed Order is made as of June 17, 2020, by and among Panthera
Enterprises, LLC (the “Debtor or Respondent”) and Darrick and Emily Gust (the “Movants”),
(together, “the Parties”):
1.
On September 13, 2019, (“Petition Date”), the Debtor filed a voluntary petition for
relief under chapter 11 of the Bankruptcy Code at case number 19-00787 (the “Bankruptcy Case”)
in the United States Bankruptcy Court for the Northern District of West Virginia (the “Court”).
2.
On May 28, 2020, the Movants filed their Motion for Relief from the Automatic
Stay to Pursue Insurance with Combined Request for Allowance of Administrative Expense Claim
(Doc. No. 152) (the “Motion”).
3.
The Court set the deadline to respond to the Motion for June 11, 2020.
4.
On June 10, 2020, the Parties filed a Stipulation and Agreed Ordering Extending
the Time for Debtor to respond to the Motion to June 18, 2020 (the “Stipulation and Order”).
5.
On June 15, 2020, the Court entered the Stipulation and Order.
No. 2:19-bk-00787    Doc 170    Filed 06/17/20    Entered 06/17/20 15:30:34    Page 1 of 2

2
6.
The Parties have been discussing a potential resolution of the Motion and are in the
process of preparing a proposed Order that would consensually resolve the Motion.
7.
In order to allow for additional time for the Parties to finalize a proposed Order
resolving the Motion, the Parties have agreed to a further extension of time for the Debtor to
respond to the Motion.
8.
The Parties have agreed to extend the response date to July 1, 2020.
NOW, THEREFORE, IT IS HEREBY STIPULATED AND AGREED TO, by and among
the undersigned, subject to the approval of the Court, the deadline for the Respondent to respond
to the Motion is July 1, 2020.
Agreed to by:

/s/ John J. Richardson

John J. Richardson, Esq., WV Bar ID: 13140
Mark A. Lindsay, Esq., PA Bar ID: 89487 (pro hac vice)
BERNSTEIN-BURKLEY, P.C.
707 Grant Street, Suite 2200
Pittsburgh, PA 15219
p. (412) 456-8100
f. (412) 456-8135
jrichardson@bernsteinlaw.com
mlindsay@bernsteinlaw.com
Counsel for Debtor, Panthera Enterprises, LLC

/s/ Spencer D. Elliot

Spencer D. Elliott (WVSB 8064)
LEWIS GLASSER PLLC
P.O. Box 1746
Charleston, WV 25326
Telephone: (304) 345-2000
Facsimile:  (304) 343-7099
E-mail:       selliott@lewisglasser.com
Counsel for Movants Darrick & Emily Gust
No. 2:19-bk-00787    Doc 170    Filed 06/17/20    Entered 06/17/20 15:30:34    Page 2 of 2

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