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Notice (2021-05-26) — In re Panthera Enterprises, LLC, Case No. 2:19-bk-00787 (Chapter 7)

What This Document Is

This is docket entry 351, a 2-page Notice of Substitution of Counsel filed May 26, 2021 by TR&L, LLC, the creditor claiming the training facility's modular buildings as SMI, LLC's successor. The docket entry text styles it a notice of appearance and request for notice by the incoming lawyer; the document itself is captioned as a substitution.

Factual Summary

TR&L, LLC, identified as "successor to SMI, LLC, creditor of the Debtor," gives notice that Kathy M. Santa Barbara and The Law Office of Kathy M. Santa Barbara, PLLC of Martinsburg, West Virginia are substituted "in the place and stead of" Steven L. Thomas, Robert L. Bandy, and Kay Casto & Chaney PLLC, and directs that all notices and pleadings thereafter be served on the new firm at the listed Martinsburg address and email accounts. The notice, dated May 26, 2021 and signed by Santa Barbara (WVSB #5960), arrives five days after the trustee's memorandum attacked TR&L's modular-buildings and timber claims, three days after service of the order continuing the contested hearings to June 22, 2021 for mediation, and during the pendency of the fraudulent-conveyance adversary proceeding (21-ap-00002) in which TR&L had counterclaimed. It is TR&L's second counsel change in the record: its April 21, 2021 objection papers had come through Kay Casto & Chaney after earlier SMI matters were handled by William J. Leon.

Key Facts

  • Docket entry: 351, filed May 26, 2021, 2 pages, with certificate of service
  • Party: TR&L, LLC, successor to SMI, LLC
  • Incoming counsel: Kathy M. Santa Barbara, The Law Office of Kathy M. Santa Barbara, PLLC, Martinsburg, WV
  • Outgoing counsel: Steven L. Thomas, Robert L. Bandy, Kay Casto & Chaney PLLC
  • Timing: between the trustee's May 21, 2021 memorandum and the June 22, 2021 rescheduled hearing

Source Caveats

This is a procedural notice; it states the substitution and service instructions only and contains no position on any contested issue. The docket entry text ("Notice of Appearance and Request for Notice") and the document caption ("Notice of Substitution of Counsel") differ slightly; both describe the same filing.

Date
2021-05-26

Full text

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

In re:

PANTHERA ENTERPRISES, LLC,

BK No. 2:19-bk-00787

Debtor.

Chapter 7

NOTICE OF SUBSTITUTION OF COUNSEL

COMES NOW, TR&L, LLC, successor to SMI, LLC, creditor of the Debtor, and
hereby gives notice of substitution of counsel in the within proceeding.  Kathy M. Santa
Barbara, Esquire and The Law Office of Kathy M. Santa Barbara, PLLC, whose address and
relevant information are as more fully set forth below, are hereby substituted in the place and
stead of Steven L. Thomas, Esquire, Robert L. Bandy, Esquire, and Kay Casto & Chaney
PLLC.  All notices and other pleadings filed in the within proceeding should hereafter be
served upon the following:
Kathy M. Santa Barbara, Esquire
The Law Office of Kathy M. Santa Barbara, PLLC
518 West Stephen Street
Martinsburg, West Virginia 25401
Telephone: (304) 264-0000
Facsimile: (304) 263-2527
kathy@ksblawofc.com
ecf email: ksantabarbara@yahoo.com
and cmarshsblo@yahoo.com

Dated this 26th day of May, 2021.

TR&L, LLC, successor to SMI, LLC

By Counsel

THE LAW OFFICE OF KATHY M.
SANTA BARBARA, PLLC

By: /s/ Kathy M. Santa Barbara

Kathy M. Santa Barbara, Esquire

WVSB #5960

518 W. Stephen St.

Martinsburg, WV 25401

(304) 264-0000

No. 2:19-bk-00787    Doc 351    Filed 05/26/21    Entered 05/26/21 16:07:40    Page 1 of 2

CERTIFICATE OF SERVICE

I, Kathy M. Santa Barbara, substitute counsel for TR&L, LLC, successor to SMI,
LLC, hereby certify that on the 26th day of May, 2021, I electronically filed the foregoing
NOTICE OF SUBSTITUTION OF COUNSEL with the Clerk of the Court using the
CM/ECF system, which will send notification of such filing to all interested parties and
creditors having entered their appearance herein.

/s/ Kathy M. Santa Barbara

Kathy M. Santa Barbara, WVSB #5960

THE LAW OFFICE OF KATHY M.

SANTA BARBARA, PLLC

No. 2:19-bk-00787    Doc 351    Filed 05/26/21    Entered 05/26/21 16:07:40    Page 2 of 2

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