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United States Bankruptcy Court

Middle District of Alabama (Dothan)
______________________________________________ In re Greg W. Howard / Sandra E. Howard, ) ) Debtor ) Case No. 10-10511 Address: 3031 Highway 134 E ) Headland, AL 36345 ) ) Chapter 13 Last four digits of Social-Security or Individual Tax) Payer-Identification No(s): 7127 / 3702 ) ______________________________________________)

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MOTION TO APPEAR TELEPHONICALLY AT OBJECTION TO PLAN CONFIRMATION HEARING ON NOVEMBER 3, 2010 Now comes Jodi B. Rowland-Lowney of the Child Support Enforcement Division of the Massachusetts Department of Revenue (MDOR/CSE) and hereby respectfully requests to appear telephonically at the hearing scheduled for November 3, 2010 at 9:30 a.m. In support MDOR/CSE states that: 1. On May 24, 2010, MDOR/CSE filed a proof of claim for a domestic support obligation under 11 U.S.C. § 507(a)(1). Claim No. 11. 2. On September 21, 2010, Debtors filed an objection to Claim No. 11. See Doc. No. 31. 3. The hearing on Debtors’ Claim Objection is scheduled for 9:30 a.m. on October 15, 2010. Counsel to the MDOR/CSE lives and works in Massachusetts and it would constitute a financial burden on counsel and the taxpayers of Massachusetts to physically appear at the hearing. 4. 5. Section 304(g) of the Bankruptcy Reform Act of 1994 (Public Law No. 103-394) provides: Child support creditors or their representatives shall be permitted to appear and intervene without charge, and without meeting any special local rule requirement for attorney appearances, in any bankruptcy case or proceeding and in any bankruptcy court or district of the United States if such creditors or representatives file a form that contains information detailing the child support debt, its status and other characteristics. Doc 35 Filed 11/02/10 Entered 11/02/10 11:53:33 Document Page 1 of 2 Case 10-10511 Desc Main

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This requirement was satisfied when MDOR/CSE filed its original Proof of Claim and Form 281. See Document No. 23 and Claim No. 11. WHEREFORE, the Child Support Enforcement Division of the Massachusetts

Department of Revenue respectfully requests that this Honorable Court allow

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MDOR/CSE’s Motion to Appear Telephonically or such other and further relief as this Court deems just and proper. DATED: November 2, 2010 /s/ Jodi B. Rowland-Lowney Jodi B. Rowland-Lowney, Esq. BBO # 667709 Department of Revenue Child Support Enforcement Division P.O. Box 9561 Boston, MA 02114-9561 (617) 626-2138 rowlandloj@dor.state.ma.us CERTIFICATE OF SERVICE I, Jodi B. Rowland-Lowney, Counsel to the Commissioner of the Child Support Enforcement Division of the Massachusetts Department of Revenue, do hereby certify that on November 2, 2010, I electronically filed the above motion using the CM/ECF system. I served the foregoing document on the following CM/ECF participants: Michael D. Brock, Esquire Curtis C. Reding, Trustee I certify that on this date I served a copy of same on the following non-CM/ECF participants listed below by first class mail, postage prepaid. Greg W. Howard / Sandra E. Howard 3031 Highway 134 E Headland, AL 36345 Signed under the pains and penalties of perjury on November 2, 2010. /s/ Jodi B. Rowland-Lowney Jodi B. Rowland-Lowney Case 10-10511 Doc 35 Filed 11/02/10 Entered 11/02/10 11:53:33 Document Page 2 of 2 Desc Main

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