700 Trust

UNITED STATES BANKRUPTCY COURT

NORTHERN DISTRICT OF FLORIDA

GAINESVILLE DIVISION

IN RE:

700 TRUST, CASE NO.: 24-10230-KKS

CHAPTER: 11

Debtor.

/

MEMORANDUM OPINION AND FINAL ORDER GRANTING, IN

PART

(ECF No. 53)

and PROVIDING NOTICE TO CERTAIN COURTS AND CLERKS

THIS CASE came before the Court for hearing on Wednesday,

December 18, 2024, on

(“Motion,” ECF No.

53), filed on behalf of Interested Parties, NAPLES PROPERTY HOLDING

COMPANY, LLC; NAPLES BEACH CLUB LAND TRUSTS TRUSTEE,

LLC, as Trustee; NAPLES BEACH CLUB PHASE II AND III LAND

TRUST TRUSTEE, LLC, as Trustee; NBC CLUB OWNER, LLC (“NBC

Entities”); and TIDES NOTE ON NOTE LENDER I, LLC (“Buyer”). Present

at the hearing were Drew M. Dillworth and Glenn Burhans, Jr., counsel to

the NBC Entities and Buyer, Michael Alan Gort, counsel to Debtor, and

Gregory B. Myers, representative and co-Trustee of Debtor, 700 Trust.

Debtor filed no written response to the Motion. Debtor argued its

opposition to the Motion at the hearing. The Court enters this Final

Order to supplement the Court’s Interim Order.1

The Motion, as filed, sought three (3) types of relief: a ruling that

the automatic stay does not apply, dismissal of the case, and sanctions

for filing the instant case. At the beginning of the hearing, the Court

granted, in part, Debtor’s motion to strike the Motion.2 The Court then

proceeded to consider and rule on only that portion of the Motion seeking

an order that the automatic stay does not apply to the NBC Entities, the

Buyer, the “Naples property” and the “Naples Litigation.” For the reasons

set forth herein, and as announced in open court at the hearing, the

Motion is due to be granted, in part, as set forth below.

1

, ECF No. 80 (“Interim Order”).

22

,

ECF No. 64 (“Motion to Strike”).

Introduction.

The filing of this case is yet another thread in the sprawling tapestry

of bad faith abuse of the bankruptcy process by the principals of 700 Trust,

Gregory Brian Myers (“Mr. Myers”) and Barbara Ann Kelly (“Ms. Kelly”),

and to a certain degree Debtor’s counsel, to avoid adverse consequences of

a myriad of legal actions spanning over a decade. Mr. Myers and Ms. Kelly

have a long and well-documented history of abusing the Bankruptcy Code,

the bankruptcy system, and other federal and state courts.

The NBC Entities and Buyer implore this Court to enforce, and

require Mr. Myers, Ms. Kelly, and their counsel to abide by the injunction

and equitable servitude imposed by the United States Bankruptcy Court

for the District of Maryland (“Maryland Bankruptcy Court”). That relief

is due to be granted. This Court must give full faith and credit to the

rulings of the Maryland Bankruptcy Court. Further, this Court does not

intend to permit Mr. Myers’ and Ms. Kelly’s and their cohorts’ abuse of

the bankruptcy process to continue. Certainly not here.

History.

In December of 2023, on motions by the NBC Entities and others

filed in Ms. Kelly’s most recent bankruptcy case, Bankruptcy Judge

Maria Ellena Chavez-Ruark entered stay relief orders that granted

prospective relief from the automatic stay and imposed an equitable

servitude on assets in which Ms. Kelly claimed ownership and that have

been embroiled in extensive litigation for over ten (10) years.3 Judge

Chavez-Ruark supported the stay relief orders by issuing a 101-page

Memorandum Opinion that sets forth in painstaking detail many of the

bankruptcy cases, civil actions, removals and appeals that comprise Mr.

Myers’ and Ms. Kelly’s continuing attacks on creditors, parties in

interest, and indeed the judicial system itself.4 Tellingly, Judge Chavez-

Ruark’s Memorandum Opinion begins and concludes thusly:

Ms. Kelly and Mr. Myers have exploited and subverted the

bankruptcy process for over eight years. It is the intention of

this Court that they be precluded from doing so any longer.

. . . .

As set forth in detail below, extraordinary relief is not only

warranted but also necessary to prevent (or, at least, curtail)

further prejudice to creditors and parties in interest. For eight

years, Ms. Kelly and Mr. Myers have exploited, manipulated,

and abused the bankruptcy process to hinder and delay

creditors from enforcing their security interests or otherwise

pursuing their claims all while forcing those same creditors to

3

, , Case No. 23-12700-MCR (Bankr. D. Md. Dec. 11,

2023), ECF No. 107;

, , Case No. 23-12700-MCR (Bankr. D. Md.

Dec. 11, 2023), ECF No. 108.

4 , 656 B.R. 541 (Bankr. D. Md. 2023).

incur substantial legal fees to protect their interests in

various state and federal courts. Ms. Kelly’s and Mr. Myers’

pattern of filing bankruptcy cases, lawsuits, and appeals and

subsequently abandoning those actions by either dismissing

them or failing to meet filing requirements forces creditors to

incur even more costs. Ms. Kelly and Mr. Myers have

demonstrated a masterful ability to subvert and pervert the

bankruptcy and litigation processes and, until now, have

enjoyed great success at abusing, harassing, and harming

innocent creditors and parties in interest. The relief being

granted by the Court is long overdue. For the reasons set forth

herein, the Court will . . . impose prospective relief designed

to protect creditors and other parties in interest from further

bad faith conduct by Ms. Kelly and, to the extent possible, by

Mr. Myers.

. . . .

Because of the extreme bad faith exhibited by Ms. Kelly . . .

the NBC Entities and U.S. Bank have been precluded from

enforcing their rights for far too long . . . .

The Court takes no pleasure in imposing such

extraordinary relief, but it is the duty of this Court to prevent

further abuse of the bankruptcy process by Ms. Kelly. The

Court determines that the relief granted is necessary and

appropriate under the unique facts of this case to protect the

integrity of the Court and the bankruptcy process.5

The instant case.

The Voluntary Chapter 11 Petition commencing this case is signed

by Mr. Myers, as Trustee of Debtor, 700 Trust.6 Mr. Myers signed the

5 , at pp. 548–50, 610–11.

6 , ECF No. 1 (“Petition”). The

Court uses the term “Debtor” in this ruling for simplicity. By doing so, the Court makes no

determination as to whether 700 Trust qualifies as a debtor eligible to file a Chapter 11

petition.

Schedules and Statement of Financial Affairs filed on behalf of 700

Trust.7 The Motion alleges that 700 Trust was formed the same day that

it filed the Petition commencing the instant case. One of the assets 700

Trust claims to own is a residence at 700 Gulf Shore Blvd. North, Naples,

Florida (the “Naples property”).8 The Naples property was sold to the

Buyer by the Clerk of Court for the Circuit Court of Collier County,

Florida, at a foreclosure sale on October 24, 2024.9 Apparently this is

where Mr. Myers and Ms. Kelly still reside.10 It is undisputed that Mr.

Myers and Ms. Kelly executed and delivered a Quitclaim Deed for the

Naples property to 700 Trust the day they, or Mr. Myers, caused 700

Trust to file the Petition commencing this case.11 700 Trust lists Mr.

Myers and Ms. Kelly as its Trustees.12 In the Quitclaim Deed purporting

to transfer the Naples property to 700 Trust, Mr. Myers and Ms. Kelly

reserved for themselves a life estate.13

7 ECF Nos. 33, 34, 50, 60, 63, 77.

8 ECF No. 63, p. 6.

9 Motion, ECF No. 53-5, Ex. E.

10 ECF No. 63, p. 31.

11 Motion, ECF No. 53-6, Ex. F, p. 2.

,

Case No. 2:24-cv-01086-JES-KCD (M.D. Fla. Dec. 13, 2024), ECF No. 23.

12 Motion, ECF No. 53-6, Ex. F, p. 2; ECF No. 63, p. 31.

13 Motion, ECF No. 53-6, Ex. F, p. 2 (“The subject Property is and will remain the Grantor’s

permanent residence and homestead within the meaning set forth in the Constitution of the

state of Florida, and the Grantor hereby reserves to Grantor a present possessory interest for

As alleged in the Motion, detailed at length in Judge Chavez-

Rourk’s Memorandum Opinion, and recounted by Middle District of

Florida Chief Bankruptcy Judge Caryl Delano in a ruling almost two (2)

years ago,14 Mr. Myers and his wife, Ms. Kelly, have been parties to a

host of actions in state and federal courts since at least 2009.15 Between

them they have filed nine (9) bankruptcy cases, excluding the instant

case for 700 Trust, myriad appeals, and numerous civil actions, most in

a continuing effort to forestall foreclosures on various properties,

including the Naples property. They have removed, or attempted to

remove, cases from one court to another on numerous occasions.16

In January of 2023 the Bankruptcy Court for the Middle District of

Florida barred Mr. Myers from filing another bankruptcy case for two (2)

life, with the right to continue to reside upon and occupy the Property as Grantor’s permanent

residence and homestead during Grantor’s lifetime, with full and exclusive possession, use

and enjoyment of the Property . . . .”). The Court takes judicial notice of the recorded

Quitclaim Deed. Fed. R. Evid. 201(c)(1); Fed. R. Evid. 803(8)(B).

14 , Case No. 2:21-bk-00123-FMD, 2023 WL 350183 (Bankr. M.D. Fla. Jan. 20,

2023).

15 , ECF No. 53-8, Ex. H.

16 Their most recent removal occurred just last month: on November 25, 2024, Mr. Myers

(through counsel to 700 Trust) filed a Notice of Removal of the Collier County, Florida, Naples

property foreclosure action to the District Court for the Middle District of Florida.

, ,Case No. 2:24-cv-01086-JES-KCD (M.D. Fla. Nov. 25,

2024), ECF No. 1. Mr. Myers then, on December 13, 2024, filed a motion to transfer the

removed action to this Court.

, Case

No. 2:24-cv-01086-JES-KCD (M.D. Fla. Dec. 13, 2024), ECF No. 23.

years.17 In December of 2023 the Maryland Bankruptcy Court barred Ms.

Kelly from filing another bankruptcy case for over four (4) years.18 The

District Court for the Middle District of Florida and the Circuit Court for

Collier County have barred Mr. Myers and Ms. Kelly from filing

additional pleadings without an attorney licensed to practice in Florida.19

The instant case is a thinly disguised attempt to continue several

years’ worth of bad faith litigation under cover of a “business trust”

formed, apparently, for the sole and exclusive purpose of continuing Mr.

Myers’ and Ms. Kelly’s bad faith legal actions. This must stop.

The Naples property does not constitute § 541 property of the estate, so

is not subject to the automatic stay.

With respect to real property, the automatic stay only applies to

property of the debtor or debtor’s bankruptcy estate.20 700 Trust claims

to hold title to the Naples property on account of a Quitclaim Deed

executed and delivered by Mr. Myers and Ms. Kelly about three (3) weeks

17

, , Case No. 2:21-bk-00123-FMD (Bankr.

M.D. Fla. Feb. 1, 2023), ECF No. 380 (that bar expires on or about January 19, 2025).

18 , 656 B.R. 541, 611 (Bankr. D. Md. 2023) (the bar issued by the Maryland

Bankruptcy Court runs for four (4) years from the date the bar order becomes final and non-

appealable). Ms. Kelly appealed the rulings by the Maryland Bankruptcy Court but did not

seek or obtain a stay of those rulings. Fed. R. Bankr. P. 8007.

19

, , No.: 1:24-cv-03127-ACR (D.D.C.

Nov. 19, 2024), ECF No. 3, p. 2, n. 1.

20 11 U.S.C. § 362(a)(2)–(5).

after the Naples property was sold at foreclosure. The Naples property is

not property of the Debtor, 700 Trust, or its bankruptcy estate.

The Court takes judicial notice of the Certificate of Sale for the

Naples property, issued by the Clerk of Circuit Court, in and for Collier

County, Florida, on October 29, 2024.21 Florida law is clear that once a

court has issued a certificate of sale as a result of a foreclosure sale, a

debtor that subsequently files bankruptcy does not have any interest in

the property sold and that property is not property of the bankruptcy

estate.22 Under Florida law, Mr. Myers and Ms. Kelly had no remaining

title to or interest in the Naples property to convey to 700 Trust after the

issuance of the Certificate of Sale. Mr. Myers and Ms. Kelly objected to

the sale of the Naples property more than ten (10) days after the

Certificate of Sale was filed, which is too late under the applicable Florida

statute.23 Even had Mr. Myers and Ms. Kelly filed a timely objection to

the foreclosure sale of the Naples property, that objection would not serve

21 Fed. R. Evid. 201(b)(2); Fed. R. Evid. 803(8)(B).

22 , Case No. 9:12-bk-17750-FMD, 2012 WL 6204858, at *3 (Bankr.

M.D. Fla. Dec. 13, 2012) (“In Florida, the property owner has the right to redeem property at

any time before the later of the filing of a certificate of sale or the time stated in the judgment

‘by paying the amount of moneys specified in the judgment, order, or decree of foreclosure.’”

(citing Fla. Stat. § 45.0315 (2011))).

23 , Case No. 2009-CA-010813 (Fla. 20th Cir.

Ct. Oct. 25, 2024), Doc. No. 1213; Fla. Stat. § 45.031(5) (2024).

to extend or preserve their right to redemption of the property.24

The Equitable Servitude prevents the automatic stay from applying as

to the Naples property or the Naples Litigation with the NBC Entities.

The Memorandum Opinion of Bankruptcy Judge Maria Ellena

Chavez-Ruark includes, among other things, an equitable servitude on

all matters pertaining to the Naples property and the Naples Litigation

between Mr. Myers, Ms. Kelly, and NBC Entities:

ORDERED, that pursuant to Section 362(d)(l) of the

Bankruptcy Code, the automatic stay is modified for cause to

the extent necessary to permit the NBC Entities to fully and

finally pursue their legal rights to dispose of all of the matters

arising from or relating to the Naples Litigation and to

liquidate the NBC Entities’ claim for costs awarded against

Ms. Kelly and Mr. Myers in connection with the Naples

Litigation; and it is further

ORDERED, that pursuant to Section 105(a) of the

Bankruptcy Code, the automatic stay imposed by Section

362(a) of the Bankruptcy Code shall not apply to the Naples

Litigation in any bankruptcy case filed in any jurisdiction of

the United States by Ms. Kelly effective immediately upon

entry of this Order . . . ; and it is further

ORDERED, that pursuant to section 105(a) of the Bankruptcy

Code, an equitable servitude is imposed effective immediately

24 510 B.R. 654, 659 (Bankr. M.D. Fla. 2014) (“Although the Debtor timely

objected to the foreclosure sale, the Objection to Sale does not serve to extend or to preserve

his right of redemption. Objections may be made to the regularity of the sale or the amount

of the deficiency, but, after the filing of the certificate of sale, the mortgagor no longer has

the ability to redeem the property. Any objection to the sale does not affect or cloud the title

of the purchaser in any manner.” (citing 186 B.R. 148, 153–54 (Bankr. M.D. Fla.

1995))).

upon entry of this Order . . . with respect to any and all real

property in which Ms. Kelly has an ownership and/or

possessory interest including, but not limited to [several

properties including the Naples property] . . . (collectively, the

“Kelly Properties”); and it is further

ORDERED, that pursuant to Section 105(a) of the

Bankruptcy Code, the automatic stay imposed by Section

362(a) of the Bankruptcy Code shall not apply to any of the

Kelly Properties in any bankruptcy case filed in any

jurisdiction of the United States by any individual and/or

entity asserting an interest in any of the Kelly Properties

effective immediately upon entry of this Order and continuing

for a period of four years after the date that this Order

becomes final and nonappealable (i.e., the date that is four

years after the date that any appeals related to this Order are

finally resolved)[.]25

This Court gives full faith and credit to this ruling of the Maryland

Bankruptcy Court. For that reason, no automatic stay is applicable to the

Naples Litigation, the Naples property, or any of the other properties

enumerated in the Maryland Bankruptcy Court’s ruling many, if not all,

of which 700 Trust lists among its assets.26

25 , 656 B.R. 541, 611 (Bankr. D. Md. 2023). Ms. Kelly appealed this ruling, and

her appeal remains pending. , Case No. 8:24-

cv-00184-DLB (D. Md. July 3, 2024). But because no stay of the ruling is in effect, the

injunction remains in full force and effect. Fed. R. Bankr. P. 8007.

26 The fact that 700 Trust was not a party to the case in which the Maryland Bankruptcy

Court entered the injunction and equitable servitude is not relevant. The Maryland

Bankruptcy Court’s ruling applies to any property in which Ms. Kelly has an ownership or

possessory interest, and to “any of the Kelly properties in any bankruptcy case filed in any

jurisdiction of the United States

. . . .” , 656 B.R. at 611 (emphasis added).

As Judge Chavez-Ruark ruled:

The equitable servitude means that Ms. Kelly and any

individuals and/or entities with an interest in any of the Kelly

Properties will be precluded from taking advantage of the

automatic stay of Section 362(a) in any bankruptcy case filed

between now and four years after the order imposing the

equitable servitude becomes final and nonappealable.27

That language clearly encompasses 700 Trust and the instant

bankruptcy case.

700 Trust must move for relief from the prospective stay relief granted

by the Maryland Bankruptcy Court.

Prospective stay relief under 11 U.S.C. § 362(d)(4), added to the

Bankruptcy Code by Bankruptcy Abuse Prevention and Consumer

Protection Act in 2005, was “intended to reduce abusive” bankruptcy

filings.28 Two (2) sections of the Bankruptcy Code provide that once a

bankruptcy court has granted prospective stay relief, as has the

Maryland Bankruptcy Court, a debtor in a subsequent case under the

Code must move for relief from the prospective stay relief order entered

in the prior case and is only entitled to relief “based upon changed

27 at 610.

28 343 B.R. 159, 166 (Bankr. D. Md. 2006) (citing H.R. Rep. 109–31(I) at

69 (2005), U.S.Code Cong. & Admin.News 2005, pp. 88, 138). 646 B.R.

389, 394 (Bankr. E.D.N.Y. 2022) (“Congress added §362(d)(4) to the Bankruptcy Code to

reduce the number of abusive filings.”).

circumstances or for other good cause shown . . . .”29 Prospective stay

relief runs with the land (and in this case the accompanying litigation).

Even if the land and its appurtenances are transferred to another, the

prospective stay relief remains in place. The debtor in a subsequent case

that claims ownership of the property, here, 700 Trust, must move for

relief from the order that imposed the prospective stay relief:

[F]uture debtors seeking the protection of the automatic stay

with respect to property subject to an order can, once

the case is filed, come before the Court and demonstrate why

they are entitled to the automatic stay. In effect, the

order places the burden on these debtors to obtain relief from

the order, as opposed to placing the burden on the

secured creditor to obtain relief from the automatic stay.

Any debtor claiming an interest in the subject property

may seek to have the stay imposed as to that property. Such

debtor needs to establish a change in circumstances or that

there is good cause to have the stay imposed. The effect of this

provision is to ship the burden onto any subsequent debtor to

come forward with evidence warranting imposition of the

automatic stay. As a result, any further filings on the eve of a

scheduled foreclosure sale will have no effect with respect to

the property unless the debtor is successful in establishing

good cause.

. . . .

This acts as a safety valve to permit the proverbial honest but

unfortunate debtor to obtain the full relief of the automatic

stay notwithstanding the entry of [a prospective stay relief

order.] When applied correctly, the comprehensive nature of

29 11 U.S.C. § 362 (b)(20) and § 362(b)(4)(B).

§ 362(d)(4) should act to circumvent abuses of the bankruptcy

system while giving a debtor a fresh start.30

The Maryland Bankruptcy Court meant its grant of prospective

stay relief to the NBC Entities and Buyer precisely as Congress intended:

“to prevent further abuse of the bankruptcy process” and to “protect the

integrity of the [bankruptcy court] and the bankruptcy process.”31 700

Trust has not moved for relief from the prospective stay relief granted by

the Maryland Bankruptcy Court, so the automatic stay did not go into

effect as to the Naples property or Naples Litigation when 700 Trust filed

this case. It is improper and disingenuous for 700 Trust, Mr. Myers, Ms.

Kelly, and their attorney to represent otherwise, which they have now

done in other courts.

Sanctions under Section 105(a) of the Code, or Rule 9011, or both.

Just prior to the hearing, 700 Trust moved to strike the Motion on

the grounds that it seeks more than one type of relief, not in the

alternative.32 At the beginning of the hearing the Court granted the

Motion to Strike, in part, without prejudice as to the NBC Entities and

Buyers’ requests for dismissal of this case and sanctions. The Court

30 646 B.R. at 396–97.

31 , 656 B.R. at 611.

32 Motion to Strike, ECF No. 64.

proceeded to consider only on that portion of the Motion seeking an order

confirming the absence of the automatic stay as to the Naples property

and Naples Litigation.

In light of the history of this case and those that preceded it, the

Court deems it appropriate to put Mr. Myers, Ms. Kelly, and attorney

Gort on notice (or remind them, as the case may be) that sanctions may

be imposed against one or more of them for filings in this case and in

others.

Fed. R. Bankr. P. 9011 provides, in pertinent part:

(b) Representations to the Court. By presenting to the

court . . . a petition, pleading, written motion, or other paper,

an attorney . . . is certifying that to the best of the person’s

knowledge, information, and belief, formed after an inquiry

reasonable under the circumstances, —

(1) it is not being resented for any improper purpose,

such as to harass or to cause unnecessary delay or needless

increase in the cost of litigation;

(2) the claims, defenses, and other legal contentions

therein are warranted by existing law or by a nonfrivolous

argument for the extension, modification, or reversal of

existing law or the establishment of new law;

(3) the allegations and other factual contentions have

evidentiary support or, if specifically so identified, are likely

to have evidentiary support after a reasonable opportunity for

further investigation or discovery . . . .33

33 Fed. R. Bankr. P. 9011(b).

The Court reserves jurisdiction to consider and determine sanctions

pursuant to 11 U.S.C. § 105(a) and Rule 9011 under a separate motion.

This reservation of jurisdiction shall apply whether or not the Court

dismisses this case or transfers this case to the Bankruptcy Court for the

Middle District of Florida.

Notice that parties connected to 700 Trust may be designated

“vexatious litigants.”

Mr. Myers and Ms. Kelly are hereby put on notice that the Court

reserves jurisdiction to consider whether they should be deemed

“vexatious litigants,” possibly subject to an additional sanction in the

form of a bar against future filings in this and other courts.34

For the reasons stated, it is

ORDERED:

1. The

(“Motion,” ECF No. 53) is GRANTED, in part, as set forth below.

34 654 B.R. 581 (Bankr. S.D. Ohio 2023);

, Case No. 20-40375-KKS, 2021 WL 1100078 (Bankr. N.D. Fla. Jan. 22, 2021).

2. This Court gives full faith and credit to the prospective stay relief

and equitable servitude imposed by the U.S. Bankruptcy Court

for the District of Maryland: , 656 B.R. 541, 611

(Bankr. D. Md. 2023).

3. The automatic stay imposed by 11 U.S.C. § 362(a) upon the filing

of the Petition in the instant case DOES NOT APPLY to the

Naples property (700 Gulf Shore Boulevard North, Naples,

Florida), or the Naples Litigation (pending litigation in state and

federal courts arising from and related to the Naples property).35

4. “The equitable servitude means that Ms. Kelly and any

individuals and/or entities with an interest in any of the Kelly

Properties [including 700 Trust] will be precluded from taking

advantage of the automatic stay of Section 362(a) in any

bankruptcy case filed between now and four years after the order

imposing the equitable servitude becomes final and

nonappealable.”36

35 As those terms are defined in the Motion and in , 656 B.R. 541, 611 (Bankr. D.

Md. 2023).

36 at 610.

5. NOTICE TO JUDGES AND CLERKS OF COURT: THE

AUTOMATIC STAY OF 11 U.S.C. § 362(a) DOES NOT APPLY

WITH REGARD TO THE BELOW-LISTED ACTIONS:

a. Myers v. Naples Golf and Beach Club, No. 1:24-cv-03127

(D.C. Cir. 2024);

b. U.S. Bank Nati Assoc. v. Kelly et al, No. 11-02009-CA-

010818 (Fla. 20th Cir. Ct. 2009);

c. U.S. Bank Nat] Assoc. v. Kelly, No. 8:24-cv-03082-PC (D.

Md. 2024);

d. U.S. Bank Nat? Assoc. v. Kelly, No. 2:24-cv-01086 (M.D.

Fla. 2024); and

e. Myers v. U.S. Bank Nati Assoc. and Deluca Law Group,

No. 2:24-cv-00370-JES-KCD (M.D. Fla. 2024).

6. The requests for sanctions in the Motion are DENIED,

without prejudice as set forth herein.

7. The request to dismiss this case is DENIED, without

prejudice.

8. The Court reserves jurisdiction for itself and any other court

to which this case may be reassigned, as set forth herein.

DONE and ORDERED on _ December 27, 2024 .

KAREN K. SPECIE

Chief U.S. Bankruptcy Judge

ce: Attorney Drew M. Dillworth is directed to serve a copy of this Order on interested parties

and file a certificate of service within 3 business days of entry of the Order.

18