`Pg 1 of 3
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`Abigail Ryan
`Texas Bar No. 24035956
`Assistant Attorney General
`Bankruptcy & Collection Division MC 008
`P. O. Box 12548
`Austin, TX 78711-2548
`Telephone: (512) 463-2173
`Facsimile: (512) 936-1409
`abigail.ryan@oag.texas.gov
`
`ATTORNEYS FOR THE STATE OF TEXAS
`
`UNITED STATES BANKRUPTCY COURT
`SOUTHERN DISTRICT OF NEW YORK
`
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`Debtors.
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`
`In re:
`
`RETRIEVAL-MASTERS CREDITORS
`BUREAU, INC.,
`
`CHAPTER 11
`
`Case No. 19-23185-rdd
`
`
`
`
`JOINDER OF THE STATE OF TEXAS IN THE RELIEF REQUSTED BY THE
`STATE OF INDIANA’S OBJECTION TO MOTION OF DEBTOR FOR ENTRY
`OF AN ORDER PURSUANT TO 11 U.S.C. §§ 105, 361, 362, 363, 364, 503, AND 507:
`(I) AUTHORIZING THE DEBTOR TO OBTAIN SECURED SUPERPRIORITY
`POSTPETITION FINANCING; (II) GRANTING LIENS AND SUPERPRIORITY
`ADMINISTRATIVE EXPENSE CLAIMS; (III) AUTHORIZING USE OF CASH
`COLLATERAL; (IV) GRANTING ADEQUATE PROTECTION; (V) MODIFYING
`THE AUTOMATIC STAY; AND (VII) GRANTING RELATED RELIEF
`
`COMES NOW the State of Texas by and through the Texas Attorney General’s Office,
`
`and respectfully files this joinder in the relief requested by the State Of Indiana’s Objection to
`
`Motion of Debtor for Entry of an Order Pursuant to 11 U.S.C. §§ 105, 361, 362, 363, 364, 503,
`
`and 507: (I) Authorizing the Debtor to Obtain Secured Superpriority Postpetition Financing; (II)
`
`Granting Liens and Superpriority Administrative Expense Claims; (III) Authorizing Use of Cash
`
`Collateral; (IV) Granting Adequate Protection; (V) Modifying the Automatic Stay; and (VII)
`
`Granting Related Relief (Dkt. 92).
`
`
`
`19-23185-rdd Doc 97 Filed 08/01/19 Entered 08/01/19 10:29:31 Main Document
`Pg 2 of 3
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`Respectfully submitted,
`
`KEN PAXTON
`Attorney General of Texas
`
`JEFFREY C. MATEER
`First Assistant Attorney General
`
`DARREN L. MCCARTY
`Deputy Attorney General for Civil Litigation
`
`RONALD R. DEL VENTO
`Assistant Attorney General
`Chief, Bankruptcy & Collections Division
`
`/s/ Abigail Ryan
`ABIGAIL RYAN*
`Texas State Bar No. 24035956
`Bankruptcy & Collections Division
`P. O. Box 12548
`Austin, Texas 78711-2548
`P: (512) 475-4297/F: (512) 936-1409
`abigail.ryan@oag.texas.gov
`
`ATTORNEYS FOR THE STATE OF TEXAS
`
`*Motion for Admission pro hac vice filed
`contemporaneously herewith
`
`
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`2
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`19-23185-rdd Doc 97 Filed 08/01/19 Entered 08/01/19 10:29:31 Main Document
`Pg 3 of 3
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`CERTIFICATE OF SERVICE
`
`
`I certify that a true and correct copy of the foregoing has been served via the Court’s
`
`Electronic Filing System on all parties requesting notice in this proceeding and that copies were
`mailed to the counsel and parties listed below via first class U.S. Mail, postage prepaid, on August
`1, 2019.
`
`
`Retrieval-Masters Creditors Bureau, Inc.
`PO Box 160
`Elmsford, NY 10523
`
`Debtor
`
`
`Serene K. Nakano
`Office of the U.S. Trustee
`201 Varick Street
`Suite 1006
`New York, NY 10014
`
`Counsel for the U.S. Trustee
`
`
`Steven Wilamowsky
`Chapman and Cutler LLP
`1270 Avenue of the Americas, 30th Floor
`New York, NY 10020
`
`Counsel for Debtors
`
`
`
`
`/s/ Abigail Ryan
`ABIGAIL RYAN
`Assistant Attorney General
`
`3
`
`
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