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IN THE UNITED STATES BANKRUPTCY COURT
FOR THE NORTHERN DISTRICT OF WEST VIRGINIA
In re:
PANTHERA ENTERPRISES, LLC,
Debtor
BK No. 2:19-bk-00787
Chapter 7
______________________________________
AARON C. AMORE, WEST VIRGINIA
ECONOMIC DEVELOPMENT
AUTHORITY, and PANTHERA
TRAINING, LLC,
Plaintiffs
v.
AP No. 2:21-ap-00002
TR&L, LLC AND SMI, LLC, THERESA
MORGOGLIONE, JAMES PUNELLI,
RAYMOND JONES, PANTHERA
TRAINING CENTER LLC and
PANTHERA WORLDWIDE LLC,
Defendants.
MOTION SHORTEN TIME PERIOD TO OBJECT TO
COMPROMISE/SETTLE ADVERSARY PROCEEDING AND RESOLVE
PENDING OBJECTIONS TO TRUSTEE’S MOTION TO SELL REAL
PROPERTY BY SMI, LLC, TR&L, LLC AND AZADIAN GROUP, LLC
Comes now Aaron A. Amore, Chapter 7 Trustee ("Trustee") and moves the
Court for approval to shorten the time period to object to the motion to
compromise/settle and settlement of certain claims as between these parties
pursuant to 11 U.S.C. §§ 105, 541, 704, and Fed. R. Bankr. P. 2002, and 9019 to
Sixteen (16) days from the service of the motion on June 2, 2021.
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The Trustee’s motion to sell has been pending since March 29, 2021 with an
initial hearing set on April 22, 2021. The matter was continued over eventually
until June 22, 2021 to accommodate a mediation related to certain objections. Three
objections were filed to the motion to sell with one being a limited objection not to
the sale itself but to the disposition of proceeds. The adversary proceeding sought to
be resolved (21-ap-2) involves the avoidance of certain transfers and declaratory
relief as to SMI, LLC, TR&L, LLC and Theresa Morgoglione. These same issues
formed the basis of an objection by TR&L, LLC to the Trustee’s motion to sell.
The mediation has resulted in the resolution of objections by TR&L, LLC and
Azadian Group, LLC. The objection of the Williams remains as of the filing of this
motion and is ripe for hearing by this Court on June 22, 2021.
Wherefore, the Trustee asks this Court for an order granting this Motion to
shorten the time period to object to his motion Compromise/Settle the claims as set
forth hereinabove.
Respectfully Submitted
Aaron C. Amore, Trustee
By Counsel:
/s/ Aaron C. Amore
Aaron C. Amore, WVSB No. 6455
AMORE LAW, PLLC
206 West Liberty Street
Charles Town, WV 25414
Phone: 304-885-4111
Facsimile: 866-417-8796
E-mail: aaron@amorelaw.com
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CERTIFICATE OF SERVICE
I hereby certify that the foregoing MOTION SHORTEN TMIE PERIOD TO
OBJECT TO COMPROMISE/SETTLE ADVERSARY PROCEEDING AND RESOLVE
PENDING OBJECTIONS TO TRUSTEE’S MOTION TO SELL REAL PROPERTY BY
SMI, LLC, TR&L, LLC AND AZADIAN GROUP, LLC was served upon the following
individuals at the addresses listed below, via CM/ECF and/or email on this 3rd day of June
2021 to the following:
Via Email:
Kelly T. Smith ksmith@sek.com
Jack Lantzy jlantzy@sek.com
Mark A. Lindsay mlindsay@bernsteinlaw.com
Rob Duncan tarpon777@yahoo.com
Rob Duncan as manager of TR&L tkelsey@woodsrogers.com
Bruce & Stacie Hardy bsrhardy@comcast.net
CM/ECF
Debra Lee Allen dallen@spilmanlaw.com
Aaron C. Amore aaron@amorelaw.com,
jackie@amorelaw.com;c.ar70274@notify.bestcase.com;alaina@amorelaw.com Aaron C.
Amore amorewvt@gmail.com,
aca@trustesolutions.net;jackiewvt@gmail.com;annwvt@gmail.com
Robert S. Bernstein rbernstein@bernsteinlaw.com,
cwirick@bernsteinlaw.com;cwirick@ecf.courtdrive.com;rbernstein@ecf.courtdrive.com
Elizabeth B. Carroll elizabeth_carroll@vawb.uscourts.gov
Julia A. Chincheck jchincheck@bowlesrice.com
Spencer D. Elliott selliott@lgcr.com
Douglas Kahle dkahle@basnightkinser.com
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Gary O. Kinder gary.o.kinder@usdoj.gov
Travis Alan Knobbe tknobbe@spilmanlaw.com, dambrose@spilmanlaw.com
Sabrina B. Lee sabrina_lee@vawb.uscourts.gov
William J. Leon jayleon@comcast.net
Salene Rae Mazur Kraemer skraemer@bernsteinlaw.com, salene@ecf.courtdrive.com,
John J. Richardson jrichardson@bernsteinlaw.com
Zachary James Rosencrance zrosencrance@bowlesrice.com, ajones@bowlesrice.com
Anita M. Swaton Anita_Swaton@wvnb.uscourts.gov
United States Trustee ustpregion04.ct.ecf@usdoj.gov
Eric Michael Wilson eric.m.wilson@wv.gov, lora.l.rutledge@wv.gov
Manual Notice List
Notice was not mailed to the parties below as no addresses were provided. To the extent the
Trustee has email addresses the below notice parties, they were emailed.
Rob Duncan
Manager/Duncan Development Group, LLC
Rob Duncan
Manager/TR&L, LLC,
a Virginia Limited Liability Company
Successor to SMI, LLC,
a Virginia Limited Liability Company
Bruce Hardy
Stacie Hardy
Anthony McIntyre
Timothy Miller
/s/ Aaron C. Amore
Aaron C. Amore, Esq.
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