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In re: § Chapter 13
§
RON WILSON AND LARHONDA WILSON, § Case No. 07-11862
§
Debtors. §
Processing Services, Inc., files this Joinder in the Motion for Reconsideration, Alteration or
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.
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
Prayer
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.
Respectfully submitted,
WINSTEAD PC
1100 JPMorgan Chase Tower
600 Travis Street
Houston, TX 77002
(713) 650-8400
(713) 650-2400 (facsimile)
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:
/s/Joseph G. Epstein
Joseph G. Epstein
Houston_1\1007133\1
48810-8 2/18/2009
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