Nolan v. Nolan

CourtUnited States Bankruptcy Court, N.D. Ohio
DecidedJuly 1, 2025
Docket23-03056
StatusUnknown

This text of Nolan v. Nolan (Nolan v. Nolan) is published on Counsel Stack Legal Research, covering United States Bankruptcy Court, N.D. Ohio primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Nolan v. Nolan, (Ohio 2025).

Opinion

The court incorporates by reference in this paragraph and adopts as the findings and analysis of this court the document set forth below. This document has been entered electronically in the record of the United States Bankruptcy Court for the Northern District of Ohio.

=) ef Ber John P. Gustafson Dated: July 1 2025 United States Bankruptcy Judge

UNITED STATES BANKRUPTCY COURT NORTHERN DISTRICT OF OHIO WESTERN DIVISION

In Re: ) Case No.: 23-31595 ) Michael V. Nolan, ) Chapter 7 ) Debtor. ) Adv. Pro. No. 23-03056 ) Paul Nolan ) Judge John P. Gustafson ) Plaintiff, ) ) Vv. ) ) Michael V. Nolan, ) ) Defendant. ) ORDER GRANTING IN PART AND DENYING IN PART PLAINTIFF’S AMENDED MOTION FOR LEAVE TO FILE SUPPLEMENTAL OR AMENDED COMPLAINT

This Adversary Proceeding is before the court on Plaintiff Paul Nolan’s (“Plaintiff”) Amended Motion for Leave to File Supplemental or Amended Complaint (“Amended Motion”) [Doc. #34], and Defendant-Debtor Michael V. Nolan’s (“Defendant-Debtor”) Memorandum in Opposition to Plaintiff’s Amended Motion for Leave to File Supplemental or Amended Complaint [Doc. #37]. In the Amended Motion, Plaintiff seeks to (1) supplement the Complaint [Doc. #1]

to include an assignment of claims per Federal Rule of Civil Procedure 15(d); and/or (2) amend the original Complaint to add certain parties. [Doc. #34, pp. 3-4, 6]. The court has jurisdiction over Defendant-Debtor’s underlying Chapter 7 case and this adversary proceeding pursuant to 28 U.S.C. §§1334, 157(a), and Local General Order 2012–7 of the United States District Court for the Northern District of Ohio. Actions to determine dischargeability are core proceedings that this court may hear and determine. 28 U.S.C. §§157(b)(1) and (b)(2)(I). For the following reasons, Plaintiff’s Amended Motion will be granted in part and denied in part.

FACTUAL BACKGROUND On September 6, 2023, Defendant-Debtor filed a voluntary petition for relief under Chapter 7 of the Bankruptcy Code, commencing Bankruptcy Case No. 23-31595. See, [Case No. 23-31595, Doc. #1]. On that same date, the court established January 1, 2024 as the statutory deadline for filing complaints objecting to discharge or dischargeability. [Id., Doc. #3].1 This deadline appears to have been reiterated in Official Form 309A issued on September 8, 2023. [Id., Doc. #7]. The

1/ By Rule, the period for filing a Complaint was extended to January 2, 2024 based upon Federal Rule of Bankruptcy Procedure 9006(a)(2)(C), because January 1st is defined as a legal holiday [Rule 9006(a)(6)(A)], and January 2, 2024 was not a legal holiday or weekend. meeting of creditors was first set for November 2, 2023. [Id., Doc. #3]. Debtor listed Paul Nolan as a creditor on the creditor Matrix and on Schedule E/F. [Doc. #1, pp. 37 & 87]. However, Tonya Nolan, Nolan Consulting LLC, and Nolan Mgmt. Group, LLC were not listed. [Id., Doc. #1, pp. 82-90; Doc. #17]. On December 28, 2023, three days before the expiration of the filing deadline under

Federal Rules of Bankruptcy Procedure2 4004(a) and 4007(c), Plaintiff filed an adversary complaint seeking to hold certain debts nondischargeable under 11 U.S.C. §§ 523(a)(2)(A), (a)(4), (a)(6), (a)(19), and to deny discharge under §727(a)(2). See, [Doc. #1].3 The Debtor timely filed an Answer to Plaintiff’s Complaint. [Doc. #8]. On February 6, 2024, the court entered a scheduling order requiring discovery to be completed by June 10, 2024. [Doc. #5].4 It appears that in the ensuing months the parties conducted substantial discovery. [Doc. #34, p. 3; Doc. #37, pp. 2-3]. Defendant-Debtor asserts that he responded to 28 discovery requests, including 6 interrogatories and 22 requests for production of documents, ultimately producing “18,803 bates numbered documents.” [Doc. #24-

1, pp. 1-2]. The Defendant-Debtor’s wife was also subpoenaed and produced an additional “6,675 bates numbered documents.” [Id.]. Plaintiff produced five documents totaling 2,711 pages. [Id.]. Both parties were deposed. [Id.]. On or about March 7, 2024, there was an assignment of claims “by and between Tonya

2/ Hereinafter generally cited as “Rule”.

3/ Citations to the record in the Adversary Proceeding will not include the Adversary Case Number. Citations to the record in the main Chapter 7case will start with the Chapter 7 bankruptcy case number.

4/ The discovery deadline was later extended to November 30, 2024. [Docs. ##18, 19]. Nolan and Nolan Consulting, LLC” to Paul Nolan. [23-31595, Claim No. 13-2]. As part of his response to the Debtor’s objection to the claim, Paul Nolan stated: “Claimant [Paul Nolan] maintained full control over the disbursement of funds to Debtor at all times, regardless of the source.” [Id., Doc. #67-4, p. 4]. The response further lists transfers that were from a “marital account” that he “authorized” Tonya Nolan to transfer. [Id., p. 3]. To date, it appears that

Plaintiff’s counsel is representing the proposed additional plaintiffs, as there has been no indication of separate counsel entering an appearance or being served. [Doc. #22, p. 3; Doc. #34, pp. 12-13]. Counsel for Plaintiff was listed on the Matrix when the Petition was filed. [23-31595, Doc. #1, p. 83]. There appears to be no question that all of the additional plaintiffs that the Amended Motion seeks to add were fully aware of the Chapter 7 case by no later than March 7, 2024. On October 30, 2024, just over 10 months after the commencement of this adversary proceeding and 237 days after filing Amended Claim 13-2, Plaintiff filed a Motion for Leave to File First Amended Complaint seeking to add new plaintiffs, including Tonya Nolan, Nolan Consulting LLC, and Nolan Mgmt. Group, LLC. [Doc. #22]. Plaintiff initially framed his Motion

for Leave to Amend as one seeking to “add Nolan Consulting, LLC as a Party Plaintiff and to make other substantive changes to conform the evidence adduced during discovery.” [Doc. #22, p. 2]. Defendant-Debtor opposed the Motion for Leave, arguing it would necessitate reopening discovery, issuing new written discovery, and conducting additional depositions. [Doc. #34, p. 11]. However, during a pretrial hearing on March 20, 2025, the court granted Plaintiff leave to file an Amended Motion for Leave. [Doc. #31]. On April 4, 2025, Plaintiff filed an Amended Motion for Leave to File Supplemental or Amended Complaint. [Doc. #34]. Defendant-Debtor filed a Memorandum in Opposition to Plaintiff’s Amended Motion to for Leave to File Supplemental or Amended Complaint on April 18, 2025. [Doc. #37]. Plaintiff – who is the managing member of both Nolan Consulting LLC and Nolan Mgmt.

Group LLC, and husband of Tonya Nolan – has already been deposed and responded to written discovery. [Doc. #34, p. 3]. Further, on February 4, 2025, the Defendant-Debtor filed an objection to Plaintiff’s proof of claim (Claim No. 13-1). Notably, although Nolan Consulting LLC claims to operate in Ohio, it is asserted that the LLC is not registered with the Ohio Secretary of State as required by R.C. §1706.511(A). Defendant responded by pointing out that the deadline for denial of discharge and actions seeking a determination of dischargeability have passed, and Nolan Consulting, LLC did not file any action against Debtor-Defendant Michael V. Nolan prior to those deadlines. Moreover,

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