Leo Stoller vs. Google Inc

Filing 4

NOTICE by Richard M. Fogel, not individually, but as chapter 7 trustee for the estate of Leo Stoller (Attachments: # 1 Exhibit)(Alwin, Janice)

Leo Stoller vs. Google Inc

Doc. 4 Att. 1

Case 1:07-cv-00092

Document 4-2

Filed 01/17/2007

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UNITED STATES BANKRUPTCY COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION In re LEO STOLLER, Debtor. Chapter 7 Case No. 05-64075 Hon. Jack B. Schmetterer District Court Case No. 07-CV-0092

STATEMENT AND RESERVATION OF RIGHTS OF TRUSTEE IN LIEU OF DESIGNATION OF ADDITIONAL ITEMS FOR RECORD ON APPEAL Richard M. Fogel, not individually, but as chapter 7 trustee (the "Trustee") for the bankruptcy estate of Leo Stoller (the "Debtor"), submits the following statement and reservation of rights in lieu of his designation of additional items for record on appeal: Background 1. On December 20, 2005 (the "Petition Date"), the Debtor filed a voluntary petition

in this Court for relief under chapter 13 of the Bankruptcy Code. The Debtor's case was converted to a case under chapter 7 on September 1, 2006 (the "Conversion Date"). The Trustee was duly appointed on September 6, 2006 to administer the Debtor's estate (the "Estate"). 2. Since the Conversion Date, the Debtor has filed four Notices of Appeal, in which

the Debtor endeavors to appeal eleven orders (whether entered or not). In fact, the Debtor has indicated on numerous occasions that he will continue to appeal each and every order of the Bankruptcy Court until he is able to reach a settlement of his bankruptcy case with the Trustee and the Debtor's creditors. 3. In light of numerous defects on the face of each of the Debtor's purported Notices

of Appeals, the pending the ruling of the U.S. District Court for the Northern District of Illinois

{5814 STA A0156945.DOC}

Dockets.Justia.com

Case 1:07-cv-00092

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Filed 01/17/2007

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in connection with certain of the Debtor's pending appeals, and the frivolous and vexatious in nature of the purported appeals, the Trustee submits this statement in lieu of his designation of additional items for the record on appeal and expressly reserves his right to supplement or amend this statement and to appropriately respond to any and all appeals of the Debtor if, when, and to the extent that the Debtor files and perfects a proper appeal. Respectfully submitted, Richard M. Fogel, not individually, but as chapter 7 trustee for the bankruptcy estate of Leo Stoller Dated: January 16, 2007 Janice A. Alwin (6277043) Shaw Gussis Fishman Glantz Wolfson & Towbin LLC 321 North Clark Street, Suite 800 Chicago, IL 60610 Tel: [phone] Fax: [phone] email: [e-mail] By: /s/ Janice A. Alwin One of his attorneys

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Case 1:07-cv-00092

Document 4-2

Filed 01/17/2007

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CERTIFICATE OF SERVICE Janice A. Alwin certifies that service of the above and foregoing notice and attached pleadings was accomplished through the Electronic Notice for Registrants on the attached CM/ECF service list, as well as upon the attached mail service list by electronic mail on this 16th day of January, 2007. /s/ Janice A. Alwin The following is the list of attorneys who are currently on the list to receive e-mail notices for this case.
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Janice A Alwin [e-mail] William J. Barrett [e-mail] Beverly A Berneman [e-mail] William J Factor [e-mail] Richard M Fogel [e-mail], [e-mail]

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Richard L Hirsh [e-mail] Sara E Lorber [e-mail] Wendy R. Morgan [e-mail] William T Neary [e-mail] Sven T Nylen [e-mail], [e-mail] August A Pilati [e-mail]

Email and Mail Service List
Leo Stoller 7115 West North Ave #272 Oak Park, IL 60302 Email: [e-mail] Lance G. Johnson Roylance, Abrams, Berdo & Goodman, LLP 1300 19th Street, NW Suite 600 Washington, DC 20036 Email: [e-mail] William J. Barrett Barack Ferrazzano Kirschbaum Perlman & Nagelberg LLC 333 West Wacker Drive, Suite 2700 Chicago, IL 60606 Email: [e-mail] Steve Wolfe Office of the U.S. Trustee, Region 11 227 W. Monroe St.Suite 3350 Chicago, IL 60606 Email: [e-mail] William J. Factor Seyfarth Shaw LLP 131 S. Dearborn St, Ste 2400 Chicago, IL 60603 Email: [e-mail] Michael Zeller Quinn, Emanuel, Urquhart, Oliver & Hedges, LLP 865 South Figueroa Street, 3rd Floor Los Angeles, CA 90017 Email: [e-mail]

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