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  • Patricia Hadfield Bankruptcy Law Group

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    NevadaGadfly
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    While Cadle Company's 3/11/13 Opposition to attorney Hadfield's 2/12/13 MSJ really wishes that Coughlin's nettlesome 4/10/12 filing had been withdrawn by either Keller or Coughlin's replacement incident to Judge Beesley's statements at the 8/28/12 status conference, that replacement, attorney Hadfield had the very good sense to recognize when a filing goes beast mode in the way Coughlin's 4/10/12. While Cadle's 3/11/13 Opposition purports that: STATUS On July 2, 2010, Defendant filed a Voluntary Petition for Relief under Chapter 7 of Title 11, U.S.C. [ECF Document 1]. The 341 Meeting was held on August 12, 2010 and Plaintiff filed its adversary complaint against Defendant Keller on October 12, 2010 with causes of action for non-dischargeability under 11 U.S.C. §§ 523(a)(2)(A), 523(a)(4) and res judicata [ECF Document 24]. After obtaining permission from the Court, Plaintiff filed its Amended Complaint on December 18, (Case 10-05104-gwz Doc 84 Entered 03/11/13 17:13:19 Page 3 of 15) 2011 [ECF Document 31]. Defendant then submitted his Answer to the Amended Complaint on January 3, 2012 [ECF Document 43]. Other than the instant Motion for Summary Judgment, all pending motions had been withdrawn by the parties at the last Status Hearing before the Court on December 4, 2012. Pursuant to an agreement of counsel, this Opposition to Defendant’s Motion for Summary Judgment will be filed on March 11, 2013." A careful inspection of Hadfield's 2/12/13 MSJ reveals the defensive collateral estoppel victory lap (kissing the track, lighting pose, draped in country's flag, finger pointing to an adoring grandstand, winning smiles) that Coughlin's failure to revive a dormant judgment within two years of its going dormant under TX Civ Code 34.001 by virtue of the the failure to effect a reivival thereof presented in Cadle's NRCP 11 violating vice president without a law license filing in 2006 of an Affidavit of Foreign Judgment in the 2JDC.

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    2 12 13 Coughlin's Replacement Hadfield in the NVB Notice of Substitution of Attorney Doc 46 10-52639 05104 0204 62337

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    While Cadle Company's 3/11/13 Opposition to attorney Hadfield's 2/12/13 MSJ really wishes that Coughlin's nettlesome 4/10/12 filing had been withdrawn by either Keller or Coughlin's replacement incident to Judge Beesley's statements at the 8/28/12 status conference, that replacement, attorney Hadfield had the very good sense to recognize when a filing goes beast mode in the way Coughlin's 4/10/12. While Cadle's 3/11/13 Opposition purports that: STATUS On July 2, 2010, Defendant filed a Voluntary Petition for Relief under Chapter 7 of Title 11, U.S.C. [ECF Document 1]. The 341 Meeting was held on August 12, 2010 and Plaintiff filed its adversary complaint against Defendant Keller on October 12, 2010 with causes of action for non-dischargeability under 11 U.S.C. §§ 523(a)(2)(A), 523(a)(4) and res judicata [ECF Document 24]. After obtaining permission from the Court, Plaintiff filed its Amended Complaint on December 18, (Case 10-05104-gwz Doc 84 Entered 03/11/13 17:13:19 Page 3 of 15) 2011 [ECF Document 31]. Defendant then submitted his Answer to the Amended Complaint on January 3, 2012 [ECF Document 43]. Other than the instant Motion for Summary Judgment, all pending motions had been withdrawn by the parties at the last Status Hearing before the Court on December 4, 2012. Pursuant to an agreement of counsel, this Opposition to Defendant’s Motion for Summary Judgment will be filed on March 11, 2013." A careful inspection of Hadfield's 2/12/13 MSJ reveals the defensive collateral estoppel victory lap (kissing the track, lighting pose, draped in country's flag, finger pointing to an adoring grandstand, winning smiles) that Coughlin's failure to revive a dormant judgment within two years of its going dormant under TX Civ Code 34.001 by virtue of the the failure to effect a reivival thereof presented in Cadle's NRCP 11 violating vice president without a law license filing in 2006 of an Affidavit of Foreign Judgment in the 2JDC.

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    Patricia Hadfield Bankruptcy Law Group

    Uploaded by

    NevadaGadfly
    While Cadle Company's 3/11/13 Opposition to attorney Hadfield's 2/12/13 MSJ really wishes that Coughlin's nettlesome 4/10/12 filing had been withdrawn by either Keller or Coughlin's replacement incident to Judge Beesley's statements at the 8/28/12 status conference, that replacement, attorney Hadfield had the very good sense to recognize when a filing goes beast mode in the way Coughlin's 4/10/12. While Cadle's 3/11/13 Opposition purports that: STATUS On July 2, 2010, Defendant filed a Voluntary Petition for Relief under Chapter 7 of Title 11, U.S.C. [ECF Document 1]. The 341 Meeting was held on August 12, 2010 and Plaintiff filed its adversary complaint against Defendant Keller on October 12, 2010 with causes of action for non-dischargeability under 11 U.S.C. §§ 523(a)(2)(A), 523(a)(4) and res judicata [ECF Document 24]. After obtaining permission from the Court, Plaintiff filed its Amended Complaint on December 18, (Case 10-05104-gwz Doc 84 Entered 03/11/13 17:13:19 Page 3 of 15) 2011 [ECF Document 31]. Defendant then submitted his Answer to the Amended Complaint on January 3, 2012 [ECF Document 43]. Other than the instant Motion for Summary Judgment, all pending motions had been withdrawn by the parties at the last Status Hearing before the Court on December 4, 2012. Pursuant to an agreement of counsel, this Opposition to Defendant’s Motion for Summary Judgment will be filed on March 11, 2013." A careful inspection of Hadfield's 2/12/13 MSJ reveals the defensive collateral estoppel victory lap (kissing the track, lighting pose, draped in country's flag, finger pointing to an adoring grandstand, winning smiles) that Coughlin's failure to revive a dormant judgment within two years of its going dormant under TX Civ Code 34.001 by virtue of the the failure to effect a reivival thereof presented in Cadle's NRCP 11 violating vice president without a law license filing in 2006 of an Affidavit of Foreign Judgment in the 2JDC.

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    of 2

    Case 10-52639-gwz Doc 46 Entered 02/12/13 14:25:50 Page 1 of 2

    , ..
    2
    " 3
    4
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    8 PATRICIA HADFIELD
    Nevada Bar No. 10890
    9 BANKRUPTCY LAW GROUP
    200 So. Virginia Street, 8
    th
    Floor
    10 Reno, NV 89501
    Tel: 775-827-9600
    11 Fax: 888-843-7260
    e-mail: PatriciaH@BankruptcyLG.com
    12
    Attorney for Debtors
    13
    14
    15
    16
    UNITED STATES BANKRUPTCY COURT
    DISTRICT OF NEVADA
    17 In Re:
    18
    19
    . 20
    21
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    ROBERT KELLER,
    Debtor .
    THE CADLE COMPANY,
    Plaintiff,
    v.
    ROBERT KELLER,
    Defendant.
    I
    I
    1
    Case No: 10-52639
    Chapter 7
    AP No. 10-05104
    DEBTOR'S SUBSTITUTION
    OF ATTORNEY AND ORDER
    APPROVING SUBSTITUTION
    Case 10-52639-gwz Doc 46 Entered 02/12/13 14:25:50 Page 2 of 2
    Debtor/Defendant Robert Keller hereby Substitutes Patricia Wilson
    2 Hadfield as his attorney for all matters pertaining to his Chapter 7 bankruptcy, including the
    3 Adversary Proceeding filed by The Cadle Company, in place and instead of his prior attorney
    4 of record, Zach Coughlin, who is presently ineligible to practice law in the State of Nevada.
    5 Ms. Hadfield's contact information is as follows:
    6
    7
    8
    9
    10
    Patricia Wilson Hadfield
    Bankruptcy Law Group
    200 S. Virginia Street, 8
    th
    Floor
    Reno, NV 89501
    Telephone: 775-827-9600
    Facsimile: 888-843-7260
    E-mail: PatriciaH@BankruptcyLG.com
    11 Ms. Hadfield acknowledges that she is aware of all pending dates in both the
    12 bankruptcy and adversary proceedings.
    13 DATED: August 28, 2012
    14
    15
    16 I accept this Appointment of Attorney and acknowledge responsibility for all
    17 pending dates and deadlines, pursuant to the requirements of Local Rule 2014. "
    18
    19 DATED: August 28, 2012
    20
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    28
    a
    PATRICIA WILS AD ELD
    Bankruptcy Law Group
    200 S. Virginia Street, 8 Floor
    Reno, NY 89501
    Tel: 775-827-9600
    2
    _________ .....;.... __________ --__ _ _ _ _ _______ _________ . - . --"'1

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