{ Converted to html. The PDF is the controlling document. JM}
Case 16-50644-btb Doc 49 Entered 09/19/19 12:01:46 Page 1 of 2
Jeffrey L. Hartman, Esq., #1607
HARTMAN & HARTMAN
Telephone: (775) 324-2800
Facsimile: (775) 324-1818
E-mail: notices@bankruptcyreno.com
Attorney for Patrick Canet, Judicial Liquidator and Foreign Representative
UNITED STATES BANKRUPTCY COURT
DISTRICT OF NEVADA
CASE NO. BK-N-16-50644-BTB
CHAPTER 15
Hearing Date: October 1, 2019
Hearing Time: 2:00 p.m.
IN RE:
GHOLAM REZA JAZI ZANDIAN,
Debtor in a Foreign Proceeding.
DECLARATION OF JEFFREY HARTMAN IN OPPOSITION TO MOTION TO DISMISS
Jeffrey
L. Hartman, under penalty of perjury of the laws of the
1. I am an attorney in good standing with the State Bar of Nevada and am admitted to practice in this Court. I have personal knowledge of the matters stated herein
2. On June 23, 2016, the Court conducted a hearing on the Petition by Patrick Canet (“Liquidator Canet”), for recognition of a foreign proceeding (“Petition”) pending in France, DE 1, against Gholam Reza Jazi Zandian (“Zandian”).
3. The Petition was opposed by Jed Margolin (“Margolin Objection”). DE 13. The Court directed Liquidator Canet to provide additional information and set August 10, 2016 for a continued hearing on the Petition. The continued hearing date was scheduled to be September 9, 2016.
4. On August 3, 2016, I filed a Status Report And Reply Re: French Proceeding Against Zandian. DE 18 and 18-1. The attachments to DE 18, identified Liquidator Canet as the liquidator in the French proceeding against Zandian.
Case 16-50644-btb Doc 49 Entered 09/19/19 12:01:46 Page 2 of 2
5. Following the filing of the Status Report and Reply, on September 7, 2016, I sent an e-mail to Margolin’s counsel, Steve Abelman, with a draft Order Granting Petition For Recognition And Chapter 11 Relief. Exhibit A.
6. On September 13, 2016, Mr. Abelman sent me an e-mail in reply, advising that the draft form of Order was acceptable. Exhibit B. Through inadvertence on my part, the proposed Order did not get lodged and was never entered.
DATED: September 19, 2019.
/S/ Jeffrey L. Hartman
Jeffrey L. Hartman, Esq.
-2-