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Case 07-11862 Doc 130 Filed 02/18/09 Entered 02/18/09 14:50:43 Main Document

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UNITED STATES BANKRUPTCY COURT


EASTERN DISTRICT OF LOUISIANA

In re: § Chapter 13
§
RON WILSON AND LARHONDA WILSON, § Case No. 07-11862
§
Debtors. §

FIDELITY NATIONAL INFORMATION SERVICES, INC.'S JOINDER IN


OPTION ONE MORTGAGE CORPORATION'S MOTION FOR RECONSIDERATION,
ALTERATION OR AMENDMENT OF ORDER DENYING MOTIONS TO QUASH DISCOVERY
[Relates to Docket No. 129]

TO THE HONORABLE ELIZABETH W. MAGNER, U.S. BANKRUPTCY JUDGE:

Fidelity National Information Services, Inc. ("Fidelity"), now known as Lender

Processing Services, Inc., files this Joinder in the Motion for Reconsideration, Alteration or

Amendment of Order Denying Motions to Quash Discovery ("Motion for Reconsideration")

filed by Option One Mortgage Corporation ("Option One"), and respectfully states the following:

Joinder

1. On February 16, 2009, Fidelity filed its Motion for Clarification of Order Denying

Motions to Quash Discovery, which sets forth the matters for clarification.

2. In addition to the relief sought by Fidelity's Motion for Clarification, Fidelity

hereby joins the Motion for Reconsideration filed by Option One and hereby adopts and

incorporates the legal arguments thereunder with respect to the pursuit of discovery by the US

Trustee from Fidelity, a non-creditor of the Debtors, outside the formal discovery process

associated with a contested matter or adversary proceeding.

Prayer

WHEREFORE, PREMISES CONSIDERED, Fidelity respectfully requests that this

Court (i) enter an order granting the relief requested in Option One's Motion for Reconsideration,

(ii) enter an Order reconsidering, altering, or amending its February 6, 2009 Order and

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Case 07-11862 Doc 130 Filed 02/18/09 Entered 02/18/09 14:50:43 Main Document
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precluding the U.S. Trustee from taking discovery through Discovery Requests, and (iii) enter

such other and further relief that the Court deems just and proper, both at law or in equity.

DATED: February 18, 2009

Respectfully submitted,

WINSTEAD PC
1100 JPMorgan Chase Tower
600 Travis Street
Houston, TX 77002
(713) 650-8400
(713) 650-2400 (facsimile)

By: /s/ Michael P. Cash


Michael P. Cash
Louisiana Bar No. 31655
Joseph G. Epstein (admitted pro hac) 1

ATTORNEYS FOR FIDELITY NATIONAL


INFORMATION SERVICES, INC., N/K/A LENDER
PROCESSING SERVICES, INC.

1
Michael Cash and Joseph Epstein were each admitted pro hac vice by this Court. See July 18, 2008 and December
10, 2008 Orders.

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Case 07-11862 Doc 130 Filed 02/18/09 Entered 02/18/09 14:50:43 Main Document
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CERTIFICATE OF SERVICE

I certify that on February 18, 2009, a true and correct copy of this document was served
on the parties below, and notice of this document will be served via ECF notice to parties
registered or otherwise entitled to receive notice in this case:

Via email Via U.S. First-class mail, postage prepaid


Elisabeth D. Harrington S.J. Beaulieu, Jr.
2901 North Causeway Blvd., Suite 303 Chapter 13 Trustee
Metairie, LA 70002 433 Metairie Road, Suite 307
Email: swamplaw@bellsouth.net Metairie, LA 70005
Counsel for the Debtors
Via Email Via email
Susan Fahey Desmond Mary S. Langston
Watkins Ludlam Winter & Stennis, P.A. Carolyn S. Cole
Post Office Drawer 160 (39502) Sean M. Haynes
2510 14th Avenue, Suite 1123 Office of United States Trustee
Gulfport, MS 39501 400 Poydras Street, Suite 2110
Email: sdesmond@watkinsludlam.com New Orleans, LA 70130
Counsel for Option One Mortgage Corporation Email: carolyn.cole@usdoj.gov
Email: mary.langston@usdoj.gov
Email: sean.m.haynes@usdoj.gov
Via Email
Kurt F. Gwynne
Reed Smith LLP
1201 Market Street, Suite 1500
Wilmington, DE 19801
Email: kgwynne@reedsmith.com
Counsel for Option One Mortgage Corporation

/s/Joseph G. Epstein
Joseph G. Epstein

Houston_1\1007133\1
48810-8 2/18/2009

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