Laserfiche WebLink
also disagree with respect to the legal standards for determining <br />the date upon which Debtor "received" the goods subject to Proler's <br />reclamation claim and for determining whether those goods remained <br />in Debtor's possession for purposes of a reclamation claim on the <br />date the notice was given. The extent to which these legal <br />disputes may be relevant will be determinable only after Proler is <br />permitted to take discovery in this case. <br />S. Proler agrees that the Debtor should pay all valid <br />reclamation claims against it, and submits that Debtor should be <br />required to pay Proler immediately the $34,099.53 portion of <br />Proler's Claim that is undisputed. Proler further requests that, <br />upon resolution of the dispute with respect to the remaining amount <br />of the Claim, the Debtor be required to pay the full remaining <br />balance of the Claim. <br />WHEREFORE, Proler International Corp. respectfully prays that <br />Debtor's Motion be denied to the extent it requests disallowance or <br />reduction of Proler's Claim; that Debtor be required to proceed on <br />any objection to Proler's Claim by way of either a contested matter <br />or adversary proceeding, or in the alternative that the Court rule <br />that the provisions of Part iX or Part VII of the Bankruptcy Rules <br />will apply in this proceeding; that Proler be permitted reasonable <br />discovery prior to any determination of Debtor's objection to <br />Proler's Claim; and that Proler be awarded all other relief to <br />which it is entitled. <br />-5- <br />