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    Several PACA Trust Beneficiaries filed an Objection to the Original PACA Trust Chart submitted in the Chapter 11 bankruptcy of Delta Produce, L.P. They objected to the Chart addressing claims for attorney's fees, as the procedure order stated fees would be dealt with later. They also objected that the Chart did not indicate some beneficiaries were seeking interest, and did not include the interest calculation for one beneficiary according to its invoices. The Objection was filed and served electronically on June 22, 2012.

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    Several PACA Trust Beneficiaries filed an Objection to the Original PACA Trust Chart submitted in the Chapter 11 bankruptcy of Delta Produce, L.P. They objected to the Chart addressing claims for attorney's fees, as the procedure order stated fees would be dealt with later. They also objected that the Chart did not indicate some beneficiaries were seeking interest, and did not include the interest calculation for one beneficiary according to its invoices. The Objection was filed and served electronically on June 22, 2012.

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    United States Bankruptcy Court For The Western District of Texas San Antonio Division

    Uploaded by

    Chapter 11 Dockets
    Several PACA Trust Beneficiaries filed an Objection to the Original PACA Trust Chart submitted in the Chapter 11 bankruptcy of Delta Produce, L.P. They objected to the Chart addressing claims for attorney's fees, as the procedure order stated fees would be dealt with later. They also objected that the Chart did not indicate some beneficiaries were seeking interest, and did not include the interest calculation for one beneficiary according to its invoices. The Objection was filed and served electronically on June 22, 2012.

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    12-50073-lmc Doc#262 Filed 06/22/12 Entered 06/22/12 20:04:16 Main Document Pg 1 of 2

    UNITED STATES BANKRUPTCY COURT FOR THE WESTERN DISTRICT OF TEXAS SAN ANTONIO DIVISION

    IN RE: DELTA PRODUCE, L.P. Debtor.

    CASE NO. 12-50073-lmc (Chapter 11)

    OBJECTION TO ORIGINAL PACA TRUST CHART

    Pursuant to the Amended Order Establishing a Deadline to File PACA Trust Claims (the

    PACA Claims Procedure Order) [D.E. 124], PACA Trust Beneficiaries Greenhouse Produce

    Co., LLC, Juniper Tomato Growers Inc., London Fruit, The Pumpkin Patch LLP, and Triple H

    Produce, LLC., have the following objections to the original PACA Trust Chart [D.E. 250-1]:

    1.

    All object to the extent that the PACA Trust Chart addresses claims for attorneys

    fees.

    The PACA Claims Procedure Order at 15 indicates that attorneys fees will be dealt with

    after all claims have been resolved.

    Page 1 of 2

    12-50073-lmc Doc#262 Filed 06/22/12 Entered 06/22/12 20:04:16 Main Document Pg 2 of 2

    2.

    The PACA Trust Chart does not indicate that Greenhouse Produce Co., LLC,

    Juniper Tomato Growers Inc., and The Pumpkin Patch LLP seek interest at the legal rate, and

    does not have a calculation for the interest Triple H Produce, LLC. is entitled to pursuant to its

    invoices.

    By:

    s/Robert E. Goldman Robert E. Goldman, Esq. (Fla. Bar #740799) Robert@goldmanlaw.com LAW OFFICE OF ROBERT E. GOLDMAN 1 East Broward Blvd., Ste. 700 Fort Lauderdale, FL 33301 (954) 745-7450 (954) 745-7460 Fax Attorney for Objectors Joe R. Hinojosa, Esq. jhinojosa@bhlawpc.com Barkhurst & Hinojosa, P.C. 110 Broadway, Ste. 350 San Antonio, Texas 78205 T 210.226-7800 F 210.226.7802 Attorney for Objectors

    CERTIFICATE OF SERVICE I hereby certify that on June 22, 2012, I electronically filed the foregoing Objection to Original PACA Trust Chart with the Clerk of the Court using the CM/ ECF system which will send a notice of electronic filing to all parties of record.

    By:

    Robert E. Goldman Robert E. Goldman

    Page 2 of 2

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