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25-10097
Bankr. S.D. Ala.
Aug 25, 2025
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Background

  • Debtor Shannon Ladon Wood filed a Chapter 13 bankruptcy petition on January 10, 2025, at 5:29 PM.
  • Official Notice of Chapter 13 (containing the proof of claim deadline) was not generated until January 13, 2025, and not transmitted to creditors until January 15, 2025.
  • The Notice informed creditors that the deadline for filing proofs of claim was March 24, 2025.
  • Quantum3 Group, as agent for Denali Capital, filed its proof of claim on March 24, 2025.
  • Debtor objected to Quantum's claim, asserting it was untimely because it was not filed within 70 days of the petition date.
  • Quantum argued its claim was timely according to the deadline stated in the court-issued Notice of Chapter 13.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Whether Quantum’s proof of claim was timely filed Claim filed after 70 days; deadline expired Filed claim by date stated in official Notice Timely; deadline in court's notice governs
Effect of incorrect or delayed notice on deadline Notice delay irrelevant; bar date strict Should rely on court-issued deadline Reliance on Notice justified; claim allowed
Applicability of strict bar date in light of due process Deadline must be strictly enforced Fundamental fairness supports claim allowance Disallowance would violate due process
Court’s authority to extend time under FRBP 3002(c)(7) Not applicable Extension appropriate per defective notice Extension justified and granted

Key Cases Cited

  • In re Gardenhire, 209 F.3d 1145 (9th Cir. 2000) (strict enforcement of proof of claim bar date required by Bankruptcy Code and Rules)
  • In re Jensen, 333 B.R. 906 (Bankr. M.D. Fla. 2005) (timeliness of proof of claim is strictly required, regardless of cause of lateness)
  • U.S. v. Cardinal Mine Supply, 916 F.2d 1087 (6th Cir. 1990) (strict deadlines for claims yield if creditor did not receive adequate notice)
  • In re Aboody, 223 B.R. 36 (1st Cir. BAP 1998) (due process requirements apply in bankruptcy proceedings, affecting claim allowance)
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Case Details

Case Name: Shannon Ladon Wood
Court Name: United States Bankruptcy Court, S.D. Alabama
Date Published: Aug 25, 2025
Citation: 25-10097
Docket Number: 25-10097
Court Abbreviation: Bankr. S.D. Ala.
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    Shannon Ladon Wood, 25-10097