IN THE UNITED STATES BANKRUPTCY COURT

FOR THE WESTERN DISTRICT OF TEXAS

SAN ANTONIO DIVISION
IN RE:
§
ANIMAL SANCTUARY OF THE § Case No. 10-54400-lmc
UNITED STATES dba §
WILD ANIMAL ORPHANAGE § (Chapter 11)
§
Debtor §

AGREED MOTION TO RESET/CONTINUE HEARING ON RONALD AND CAROL

ASVESTAS' MOTION TO LIFT AUTOMATIC STAY

TO THE HONORABLE BANKRUPTCY COURT:

Now comes RON and CAROL ASVESTAS (collectively “ASVESTAS” herein) and file

this their Agreed Motion to Reset/Continue Hearing on Ronald and Carol Asvestas Motion to

Lift Stay Against Property of the Estate and states as follows:

1. The Movants filed their Motion to Lift Stay Against Property of the Estate on March

13, 2011. The Court set the hearing for April 6, 2011 at 9:30 am. Counsel for the Debtor

contacted the undersigned and requested that the hearing be postponed, among other reasons, so

that the parties may discuss the hearing and attempt to narrow the contested issues that will be

presented to the Court. The undersigned agrees to move the hearing. The undersigend counsel

prefers a hearing date of April 13, 2011 or April 14, 2011 but opposing counsel requests a two

week continuance.

WHEREFORE, premises considered, the Movant requests that the Court reset the

scheduled April 6, 2011 hearing on RONALD and CAROL ASVESTAS' Motion to Lift

Automatic Stay Against Property of the Estate and for whatever other and further relief may be

necessary to do justice in this matter.

1
 Respectfully Submitted on this the 5th of April, 2011

/s/ Lance Geppert

Lance Geppert
Attorney at Law
State Bar No. 24007234
1900 Tower Life Building
310 South St. Mary's St., Suite 1900
San Antonio, Texas 78205
(210) 223-2641/ (210) 316-0000 Phone
(210) 223-2714/ (210) 855-9990 Fax
lgeppert@grandecom.net
Attorney for Movant Ron and Carol Asvestas

CERTIFICATE OF SERVICE
I hereby certify that on this 5th day of April, 2011, a true and correct copy of the foregoing
Motion to Lift Stay has been provided electronically to all persons entitled to notice and able to
receive same, including specifically the Trustee and Counsel for Debtor, and otherwise through
United States Mail.

/s/ Lance Geppert

Lance Geppert