Free Response to Motion - District Court of Delaware - Delaware

Case 1:06-cv-00664-SLR

Document 13

Filed 10/31/2007

Page 1 of 3

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE WELLS FARGO BANK, N.A., Appellant, vs. CHLIS LORRAINE DEAN, Appellee. ) ) ) ) ) ) ) ) )

Civil No. 06-664-SLR (on appeal from an Order of the United States Bankruptcy Court for the District of Delaware, Case No. 06-10145-BLS (Chap. 13) Docket No. 9

DEBTOR'S AMENDED RESPONSE TO WELLS FARGO BANK, N.A.'S MOTION FOR RECONSIDERATION OF ORDER DISMISSING CASE The Debtor, Chlis Lorraine Dean, by Counsel, hereby responds to the Motion for Reconsideration of Order Dismissing Case filed by Wells Fargo Bank, N.A. ("Wells Fargo") as follows: 1. 2. 3. 4.-5. 6. Admitted. Admitted. Admitted. Debtor is without sufficient information to admit or deny these allegations. Admitted. However, the appeal was not timely filed and negotiations were not

done in good faith by Wells Fargo.

Case 1:06-cv-00664-SLR

Document 13

Filed 10/31/2007

Page 2 of 3

WHEREFORE, the Debtors pray that Wells Fargo's motion to reconsider order dismissing case be denied and such other relief as this Court deems appropriate. Respectfully Submitted, CYNTHIA L. CARROLL, P.A.

/s/ Cynthia Carroll Cynthia L. Carroll, Esquire Attorney for the Debtor 260 Chapman Road, Suite 201-D Newark, DE 19702 (302) 733-0411 (Telephone) (302) 733-0511 (Facsimile) Dated: October 30, 2007

Case 1:06-cv-00664-SLR

Document 13

Filed 10/31/2007

Page 3 of 3

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE WELLS FARGO BANK, N.A., Appellant, vs. CHLIS LORRAINE DEAN, Appellee. ) ) ) ) ) ) ) ) )

Civil No. 06-664-SLR (on appeal from an Order of the United States Bankruptcy Court for the District of Delaware, Case No. 06-10145-BLS (Chap. 13) Docket No. 9

CERTIFICATE OF SERVICE I, Cynthia L. Carroll, Esquire, hereby certify that on this 30th day of October 2007, I caused a copy of the foregoing Amended Response to the Motion for Reconsideration of Order Dismissing Case to be served via first class mail, postage prepaid on the following: Adam Hiller, Esquire Draper & Goldberg, P.L.L.C. 1500 North French Street, 2nd Floor Wilmington, DE 19801 John Kerns 187 Brittney Lane Hartly, DE 19953 Chlis Dean 7 Blue Hen Ridge Newark, DE 19711

/s/ Cynthia L. Carroll Cynthia L. Carroll, Esquire

Dated: October 30, 2007