Case 15-42460

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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 plainti 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 Duy to be principals of Prenda Law, Inc.); see also Lightspeed Media v.
Smith, 761 F.3d 699, 705 (7th Cir. 2014) (discussing Debtors 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].

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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. Debtors 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

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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 Courts Electronic Case Filing System. Parties may access this filing through
the Courts 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