ACCEPTED
05-13-00228-CV
FIFTH COURT OF APPEALS
DALLAS, TEXAS
8/7/2015 8:37:26 AM
LISA MATZ
CLERK
Cause No. 05-13-00228-CV
IN THE FILED IN
COURT OF APPEALS FOR THE 5th COURT OF APPEALS
FIFTH JUDICIAL DISTRICT OF TEXAS DALLAS, TEXAS
8/7/2015 8:37:26 AM
AT DALLAS
LISA MATZ
Clerk
BEATRIZ PANGILINAN and
CAREWORKS HOME HEALTH SERVICES, INC.
Appellants,
vs.
NARCISSA VITERBO BARDELOZA and
EDUARDOBARDELOZA
Appellees.
Appealed from the 14th Judicial District Court of
Dallas County, Texas
RESPONSE TO THE COURT'S REQUEST FOR AN UPDATE ON THE STATUS OF
BANKRUPTCY PROCEEDINGS
TO THE HONORABLE JUDGE OF SAID COURT:
COME NOW, Appellants Beatriz Pangilinan ("Pangilinan") and Careworks Horne Health
Services, Inc. ("Careworks"), and pursuant to the Court's request for an update on the status of
Ms. Pangilinan's bankruptcy proceedings, respectfully present the following:
1. On May 2, 2013, Ms. Pangilinan filed a voluntary petition for relief pursuant to
Chapter 11 of Title 11 of the United States Code initiating the following styled Chapter 11 cases:
Jn re: Beatriz Pangilinan, Cause No. 13-41132, in the United States Bankruptcy Court for the
Eastern District of Texas (Sherman Division).
Response to the Court's Request for an Update on the Status of Bankruptcy Proceedings Page I of 3
l:IDEFENDANTS\CareworksHomeHealth\Pleadings\D's Resp to Court Appeals Request for Status on Bankruptcy Proceedings.doc
2. Ms. Pangilinan's bankruptcy attorney in the cause number referenced above is
Mr. Peter C. Lewis, Scheef & Stone, LLP, 500 N. Akard, Suite 2700, Dallas, Texas 75201,
telephone number 214-706-4200.
3. Ms. Pangilinan's bankruptcy case is still open and pending in the United States
Bankruptcy Court for the Eastern District of Texas (Sherman Division).
4. However, it is currently anticipated that a final order of discharge will be entered
in Ms. Pangilinan's bankruptcy case within the next ninety (90) days.
Respectfully submitted,
WALKER BRIGHT P.C.
100 North Central Expressway, Suite 800
Richardson Texas 75080
Telephone: (972) 744-0192
Facsimile: (972) 744-0067
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Arthur L. Walker, Jr.
State Bar No. 20693900
Gerald Bright
State Bar No. 02991720
David L. Craft
State Bar No. 00790522
ATTORNEYS FOR APPELLANTS
Response to the Court's Request for an Update on the Status of Bankruptcy Proceedings Page 2 of 3
I:\DEFENDANTS\CareworksHomeHealth\Pleadings\D's Resp to Court Appeals Request for Status on Bankruptcy Proceedings.doc
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing pleading/motion was served
via facsimile, overnight mail and/or by certified mail, return receipt requested, on this 3RD day of
August, 2015.
Christopher Kalis Via Facsimile to: (214) 871-6050
5160 Village Creek Drive, Suite 100
Plano, Texas 75093
Attorney for Plaintiffs
Gerald Bright/David Craft
Response to the Court's Request for an Update on the Status of Bankruptcy Proceedings Page 3 of3
l:\DEFENDANTS\CareworksHomeHealth\Pleadings\D's Resp to Court Appeals Request for Status on Bankruptcy Proceedings.doc