Neil Gordon will not provide pay offs Jan 4 2018
Fwd: Claudio Avendano- case no. 15-64523
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2018-01-04 09:25
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Claudio see below Neil is intent on running his show and not cooperating with us. I'm afraid for me to file an appearance and conduct 2004 examinations will be cost prohibitive I will check on Dave Lefkowitz the mal practice attorney did you call him? Best regards. Ted
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Begin forwarded message:
From: "Gordon, Neil C." <Neil.Gordon@AGG.com>
Date: January 4, 2018 at 10:17:28 AM EST
To: Theodore Stapleton <tstaple@tstaple.com>
Cc: "Matthews, William D." <William.Matthews@AGG.com>
Subject: Re: Claudio Avendano- case no. 15-64523
Ted, I am out of town until Tuesday. Have you filed an appearance for the debtor in this case? If so, I haven't seen it. When you do, please communicate with Bill Matthews.
We have already spent an inordinate amount of time discussing the case with you in the expectation you would file an appearance. Accordingly, we will not respond further to you and will object to any BR 2004 exam requests. Feel free to fly to Santiago to take the examination of our special counsel to try and get an estimate of their fees should the court permit it. I am not going to provide estimates in a case this fluid just so the debtor can resume objecting to everything and running up even more fees. We will wait for the appearance and a solid, credible explanation of how a homeless debtor can payoff the creditors and the estate. Of course, you are free to contact counsel to the creditors or object to their claims once you make an appearance. I am not going to provide their asserted payoffs. They need to provide that to you directly.
Neil
Sent from my iPad
On Jan 4, 2018, at 7:47 AM, "Theodore Stapleton" <tstaple@tstaple.com> wrote:
Neil- Happy New Year hope you had a good holiday. I have been waiting for a payoff of creditors and estimated administrative expenses to pay of the case since October can you please provide this information. Do I need to take 2004 exams of the creditors and the trustee to get it? Please call to discuss. Best regards, Ted
Theodore N. Stapleton
Theodore N. Stapleton, PC
Suite 100-B
2802 Paces Ferry Road
Atlanta, GA 30339
P- 770-436-3334
F- 404-935-5344
theodorestapletonlaw.com