UNITED STATES BANKRUPTCY COURT DISTRICT OF MINNESOTA

In re: Chapter 13 Case

Paul Hansmeier, Bky. No. 15-42460 (KHS)

Debtor

Objection to Confirmation of Chapter 13 Plan Alan Cooper objects to the confirmation of the Chapter 13 Plan filed by Paul Hansmeier on the grounds that it fails to adequately address whether or not debts owed by third party entities are to be addressed by the plan. In particular:

1. Cooper is a plaintiff in a case Cooper v. Steele, et al., in Hennepin County (Case No. 27-cv-13-3463) where Prenda Law, Inc., is a defendant.

2. Various courts have made findings of fact that Debtor is a principal of Prenda Law, Inc. and other related entities. See e.g. Ingenuity13 v. Doe, C.D. Cal., Case No. 12-cv-8333 (May 6, 2013)(finding Debtor, along with John Steele and Paul Duffy to be principals of Prenda Law, Inc.); see also Lightspeed Media v. Smith, 761 F.3d 699, 705 (7th Cir. 2014) (discussing Debtor’s relationship to Prenda Law, Inc. and “Alpha Law Firm” also owned by Debtor, “the district court had ample reason to find the Prenda/Alpha distinction illusory at best, fraudulent at worst.”)

3. Prenda Law, Inc. defaulted in Cooper v. Steele, et al., on April 27, 2015 and on July 15, 2015 that court entered an order for judgement against Prenda Law, Inc. for $255,000.

4. Debtor in his petition lists Cooper v. Steele, et al. as a case to which he was a party within the past year. [Doc. 1 at 35].

�1

Case 15-42460 Doc 29 Filed 10/13/15 Entered 10/13/15 20:57:22 Desc Main Document Page 1 of 3

5. However, Debtor was not a named party in Cooper v. Steele, et al., but rather series of entities he controlled were parties, namely Prenda Law, Inc., AF Holdings, LLC, and Ingenuity13, LLC.

6. Debtor’s plan does not account for any of the debts owed by his controlled entities such as Prenda Law, Inc.

7. However, by listing cases such as Cooper v. Steele, et al. in the petition, as if Debtor was a party, but failing to describe such debts in his plan, Debtor confuses whether or not such cases are subject to the plan.

8. To that extent, Cooper objects to the Plan because it is unclear whether Debtor intends to include or exclude from the Plan debts owed by Prenda Law, Inc.

DATED: October 13, 2015 Respectfully submitted,

By: /s/ Paul Godfread Paul Godfread (Mn Bar No. 389316) Godfread Law Firm, P.C. 6043 Hudson Road, Suite 305 Woodbury, MN 55125 Phone: 1-612-284-7325 Fax: 1-612-465-3609 paul@godfreadlaw.com Attorney for Alan Cooper

�2

Case 15-42460 Doc 29 Filed 10/13/15 Entered 10/13/15 20:57:22 Desc Main Document Page 2 of 3

CERTIFICATE OF SERVICE

I hereby certify that on October 13, 2015, a copy of the foregoing was filed electronically. Notice of this filing will be sent to the following parties through the Court’s Electronic Case Filing System. Parties may access this filing through the Court’s system.

DATED: October 13, 2015 By: /s/ Paul Godfread Paul Godfread (Mn Bar No. 389316) Godfread Law Firm, P.C. 6043 Hudson Road, Suite 305 Woodbury, MN 55125 Phone: 1-612-284-7325 Fax: 1-612-465-3609 paul@godfreadlaw.com Attorney for Alan Cooper

�3

Case 15-42460 Doc 29 Filed 10/13/15 Entered 10/13/15 20:57:22 Desc Main Document Page 3 of 3