RICHARD SCHMIDT, Bankruptcy Judge
Tom C. Wheat, Creditor Trustee of the Reorganized Kleberg Law Firm ("Trustee"), appointed pursuant to the confirmed First Amended Plan of Reorganization ("Plan") in the referenced case moves this Court to extend the time to object to claims and bring actions and would show:
1. Pursuant to the Plan, and the Court's order confirming the Plan ("Confirmation Order") and at the Trustee's request, the Court has previously extended to July 7, 2005, the time within which claim objections can be investigated and filed and causes of action investigated and initiated. Given the speed at which this case progressed (filed on petition date and confirmed in three months), many issues that might have been resolved in a typical chapter 11 case, prior to Plan filing or confirmation, have not yet been resolved in this case.
2. Counsel for the Trustee has filed and has been prosecuting an Omnibus Objections to Proofs of Claim, which should resolve a majority of the claims that the Trustee seeks to challenge. Today, the Trustee also filed three complaints related to various disputes between the Debtor and the Debtor's shareholders and former shareholders. The Trustee anticipates that between the Omnibus Objection and the multiple outstanding complaints, 95% of all litigation or objections that are going to be raised have been raised. In an abundance of caution, however, the Trustee requests a further extension. One small matter still has not been raised regarding a subtenant rent payment that was never received, despite a settlement. The amount is so small the Trustee is reluctant to file suit, but does not want to lose the right to do so. Also, the Trustee anticipate some litigants might try to tie the Trustee's hands with Court imposed deadlines. For those reasons, the Trustee requests a further extension.
3. The Trustee requests that the Court extend for another 120 days the time within which any claim objection, or "any other adversary proceeding, contested matter, motion, or application" can be filed with the Court to preserve the Trustee's rights (i) to assert counterclaims against existing claimants who may raise unanticipated defenses and (ii) to bring actions if necessary against existing parties for existing claims or to subordinate existing claimants equity interests as would be appropriate.
4. The Trustee requests that the Court extend this deadline to January 10, 2006, so that the Trustee has sufficient time to negotiate all matters upon which the Trustee may need to file claim objections or adversaries and to properly wind down this bankruptcy estate.
WHEREFORE, premises considered, the Creditor Trustee requests that the Court extend the deadline as requested herein and grant such other and further relief as the Court shall deem just.
ORDER GRANTING FOURTH MOTION TO EXTEND TIME TO OBJECT TO CLAIMS AND BRING ACTIONS
On the date set forth below, the Court considered the Fourth Motion to Extend Time To Object to Claims and Bring Actions ("Motion") filed by Tom C. Wheat, the Creditor Trustee of the Reorganized Kleberg Law Firm a Professional Corporation ("Debtor"). After consideration of the Motion, the pleadings of record, and the arguments of counsel, if any, the Court has determined that the Motion is well taken and should be granted. It is therefore
ORDERED that the Motion is granted and the time for the Debtor to file its objection to claims and bring actions in this case is extended to January 10, 2006.