Case 19-33568-mvl7 Doc 90 Filed 09/21/20 Entered 09/21/20 16:46:18 Page 1 of 2

IN THE UNITED STATES BANKRUPTCY COURT

FOR THE NORTHERN DISTRICT OF TEXAS
DALLAS DIVISION

IN RE: § Case No. 17-33568-7

§
Eric C. Blue, et al.,1 § Chapter 7
§
Debtors. § (Jointly Administered)

ERIC BLUE’S EMERGENCY MOTION

TO CONTINUE SEPTEMBER 22, 2020 SHOW-CAUSE HEARINGS

1. This Court has set significant show-cause matters for hearing concerning Mr. Blue
and this bankruptcy case on September 22, 2020 at 9:30 a.m. (the “Show-Cause Hearing”).

2. This afternoon, Mr. Blue retained undersigned bankruptcy counsel to advise him
concerning this bankruptcy case and the matters pending before the Court. His counsel has not
had sufficient time to fully review, consider, and advise Mr. Blue concerning the matters.

3. The Show-Cause Hearings concern serious matters and Mr. Blue respectfully
requests a two-week continuance of the Show-Cause Hearings so he may discuss the matters with
his new counsel.2 This would also give his new counsel time to further confer with the Trustee’s
counsel to attempt to remedy the outstanding issues pending before the Court.

4. Undersigned counsel has conferred with counsel for the Trustee, Mr. Fareed
Kaisani via phone and follow-up emails to request a one-week continuance. Undersigned is not
yet sure if Mr. Kaisani’s client Trustee approves of the requested continuance but believes it is
under consideration.

WHEREFORE, PREMISES CONSIDERED, Mr. Blue respectfully requests a one or two

week continuance of the September 22, 2020 Show-Cause Hearings and for such other relief as is
appropriate.

1
The jointly administered Debtors are named to include Eric C. Blue, Capital Park Management
Company, LLC, and Capital Park Private Equity Partners, LLC

2
Lead undersigned counsel had a conflict before another bankruptcy court at the same day and
time as the Show-Cause Hearing; however, given the gravity of the issues before this Court, Mr.
Rowe will be handling the other conflicting case so Mr. Castillo may appear on the Show-Cause
Hearing as needed.
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Case 19-33568-mvl7 Doc 90 Filed 09/21/20 Entered 09/21/20 16:46:18 Page 2 of 2

Dated: September 21, 2020 Respectfully submitted,

/s/ Mark A. Castillo

Mark A. Castillo
Texas State Bar No. 24027795
Robert C. Rowe
Texas State Bar No. 24086253
CURTIS | CASTILLO PC
901 Main Street, Suite 6515
Dallas, Texas 75202
Telephone: 214.752.2222
Facsimile: 214.752.0709
Email: mcastillo@curtislaw.net
rrowe@curtislaw.net

COUNSEL FOR ERIC C. BLUE

CERTIFICATE OF CONFERENCE

The undersigned certifies that, prior to filing this Motion, he conferred via phone and email
with counsel for the Trustee. Undersigned believes the Trustee may be unopposed to a brief
continuance of about a week, but has not received confirmation in writing since the request was
only recently made on Friday and the retention only recently occurred this afternoon. Counsel are
still communicating via email and undersigned will update the Court via email if agreement is
reached.

/s/ Mark A. Castillo

Mark A. Castillo

CERTIFICATE OF SERVICE

The undersigned certifies that, on September 21, 2020, a true and correct copy of the
foregoing document was served by the Court’s CM/ECF system on all parties requesting or
consenting to such service in this case.

/s/ Mark A. Castillo

Mark A. Castillo

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