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Case 1:20-bk-12043 Doc 621 Filed 02/24/21 Entered 02/24/21 14:52:42 Desc Main <br /> Document Page 3 of 40 <br /> and Southern Districts of West Virginia and has routinely obtained credentials for other filings. <br /> 13. That immediately upon being hired, the Law Firm communicated with the clerk of <br /> the United States Bankruptcy Court Southern District of Ohio, Western Division of Dayton in <br /> order to obtain proper credentials to file the proof of claim. <br /> 14. That the clerk's office directed this Law Firm's staff to contact the PACER IT <br /> department. <br /> 15. That repeated calls were made to the PACER IT department and all instructions <br /> were followed but the electronic credentials were not timely provided. j <br /> i <br /> 16. That on or about December 15,2020,having not received credentials with which <br /> I <br /> to E-file and being told by PACER and the clerk that there was no way to expedite the matter,the <br /> Law Firm did mail to the Proof of Claim for by United States Certified Mail,return receipt 4 <br /> requested addressed to U.S. Bankruptcy Court Hopedale Mining, P.O. Box 4421, Beaverton, OR <br /> 97076-4421. (See Exhibit B and C) <br /> r <br /> F <br /> 17. That a return receipt card was provided by the United States Postal Service and <br /> received by the office of the Law Firm on or about December 22, 2020, but the document did not : <br /> have the date that it had been signed for by the clerk's office.(See Exhibit D) <br /> 18. That sometime later the claimant discovered that the claim had been listed as -0- <br /> in the Debtors case because the claims bar date was December 17, 2020, and the claim of <br /> Kenneth Cole and Billie Cole was not docketed until December 18,2020, less than twenty-four <br /> (24)hours after the running of the claims bar date. <br /> ik <br /> BASIS FOR RELIEF REQUESTED I <br /> J <br /> 19. Federal Rule of Bankruptcy Procedure 9006(b) allows the Claims Bar Date to be <br /> k <br /> t <br /> 1 <br />