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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 6 of 40 <br /> Counsel. On the contrary, Kenneth Cole, Billie Cole and Counsel have acted consistently to <br /> provide notice to the Debtors of the claims against them. <br /> 31. Moreover, once the late filing was discovered by Counsel, Counsel promptly <br /> sought leave, in the form of the instant motion, to permit the Proofs of Claim in question to be <br /> deemed timely filed. <br /> 32. It is respectfully submitted that based upon the foregoing, there is sufficient cause <br /> for the Court to find excusable neglect on the part of Kenneth Cole and for the Court to deem <br /> Kenneth and Billie Cole's Proofs of Claim as to the Debtors timely filed. <br /> I <br /> WHEREFORE, Kenneth Cole seeks the entry of an Order granting the instant Motion, j <br /> deeming their Proofs of Claim as timely filed, and granting such other and further relief as the <br /> i <br /> Court deems just and equitable. <br /> E <br /> a <br /> /s/James M. Pierson <br /> James M. Pierson, Esq. (WVSB#2907) <br /> PIERSON LEGAL SERVICES 1 <br /> s <br /> 5300 MacCorkle Ave. S.E. <br /> P.O. Box 2291 <br /> Charleston, WV 25328 ; <br /> i <br /> f <br /> t <br /> 3 <br /> 1 <br /> a <br /> f <br /> i <br /> z <br /> i <br /> { <br /> i <br /> I <br /> 1 <br /> f <br />