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UNITED STATES BANKRUPTCY COURT

EASTERN DISTRICT OF LOUISIANA

In re: BANKRUPTCY CASE NO. 07-11862

SECTION “A”
RON WILSON and
LaRHONDA WILSON, CIVIL ACTION NO. 09-2381
SECTION “F” MAG “2"
Debtors.
CHAPTER 13

RELIEF REQUESTED FROM A

DISTRICT COURT JUDGE

UNITED STATES TRUSTEE’S ANSWER IN OPPOSITION TO

FIDELITY NATIONAL INFORMATION SERVICES, INC.’S MOTION FOR LEAVE
TO APPEAL PURSUANT TO 28 U.S.C. § 158(a)(3)

The United States Trustee, Region 5 (the “United States Trustee”), by and through his

duly authorized counsel, pursuant to 28 U.S.C. § 158(a) and Fed. R. Bankr. P. 8001 and 8003,

hereby answers in opposition to the motion [Docket No. 150] filed by Lender Processing

Services, Inc., f/k/a Fidelity National Information Services, Inc. (“Fidelity) for leave to appeal

(the “Motion for Leave”) the bankruptcy court’s February 6, 2009 order denying Fidelity’s

motion to quash [Docket No. 123, Exhibit 1 & Docket No. 124, Exhibit 2], and March 27, 2009

order denying Fidelity’s motion for clarification [Docket No.143].1 The United States Trustee

respectfully states as follows:

1
Pursuant to Fed. R. Bankr. P. 8003, Fidelity’s Motion was filed in the bankruptcy court seeking relief
from the United States District Court for the Eastern District of Louisiana. Accordingly, the UST’s Objection
follows the same convention. Except as otherwise noted, all references to docket entries refer to the bankruptcy case
pending before the United States Bankruptcy Court for the Eastern District of Louisiana, Case No. 07-11862 and are
designated “Docket No. ___.”
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SUMMARY OF ARGUMENT

Option One Mortgage Corporation (“Option”) filed a motion to lift stay that was

supported by an affidavit the bankruptcy court determined to be “false.” In re Wilson, 2009 WL

304672, *2 (Bankr. E.D. La. 2009). The affidavit was signed by Dory Goebel, who is both an

officer and employee of Fidelity. Id. at *1-2. The bankruptcy court initiated collateral

proceedings concerning the filing of the false affidavit. See id. at *3. The United States Trustee2

appeared in the bankruptcy case and requested the entry of a scheduling order on the bankruptcy

court’s collateral proceeding. [Docket Nos. 40 & 41]. The United States Trustee then issued

formal discovery requests to Fidelity. Fidelity sought to quash the United States Trustee’s

discovery requests, however, the bankruptcy court denied Fidelity’s motion to quash and

subsequent motion for clarification. Fidelity seeks to appeal those discovery orders.

Interlocutory appeals of discovery orders are ordinarily denied to avoid piecemeal

litigation. At a minimum the movant must demonstrate exceptional circumstances, which do not

exist here. Moreover, appellate review of discovery orders is available from a final order of

contempt.

2
The United States Trustee is an official of the United States Department of Justice charged by statute to
oversee and supervise the administration of bankruptcy cases. 28 U.S.C. § 586(a). The United States Trustee acts as
a “watchdog” whose role “may be compared with . . . a prosecutor.” H.R. Rep. No. 95-595, 1 st Sess. 4, 110 (1977),
as reprinted in 1978 U.S.C.C.A.N. 5963, 5966, 6071. The legislative history regarding the creation of the United
States Trustee Program describes the proposed United States Trustee as the “enforcer[] of the bankruptcy laws,” and
notes that the United States Trustee would be responsible for bringing “proceedings in the bankruptcy courts in
particular cases in which a particular action taken or proposed to be taken deviate[d] from the standards established
by the . . . bankruptcy code.” H.R. Rep. No. 95-595, 1st Sess. 109 (1977), as reprinted in 1978 U.S.C.C.A.N. 5963,
6070.

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Fidelity urges this Court to consider the factors set forth in 28 U.S.C. § 1292(b) in

exercising its discretion to grant Fidelity leave to appeal. However, Fidelity fails to demonstrate

the appropriateness of an appeal under those conjunctive factors. Therefore, the Motion for

Leave must be denied.

BACKGROUND

1. Option filed a motion to lift stay, seeking termination of the 11 U.S.C. § 362

automatic stay with respect to the home of the debtors, Ron and LaRonda Wilson. [Docket No.

20]. Option supported its motion with an affidavit of debt signed by Dory Goebel. Id.

2. In connection with Option’s motion to lift stay, the Court entered its May 9, 2008

Order to Show Cause (the “Show Cause Order”). [Docket No. 30] requiring certain persons to

appear on June 26, 2008 “to explain the amounts due on the mortgage loan” of the debtors.

3. After a hearing on June 26, 2008, at which Dory Goebel failed to appear, the

bankruptcy court denied the motion to lift stay. [Docket No. 36].

4. On June 30, 2008, the United States Trustee filed a Notice of Appearance in the

instant case. [Docket No. 40]. The United States Trustee simultaneously filed a motion

requesting that the bankruptcy court enter a scheduling order in connection with the proceeding

surrounding the Show Cause Order. That motion was granted pursuant to an order entered by the

bankruptcy court on July 11, 2008.

5. In connection with its findings at the June 26, 2008 hearing, the bankruptcy court

entered two additional orders on July 11, 2008. First, the court entered an order continuing its

Show Cause Order and directing that Dory Goebel and a representative of Option One appear on

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August 21, 2008 and explain the amounts due on the mortgage loan of the Debtors. [Docket No.

46]. That Order also decreed that “Dory Goebel and Option are jointly sanctioned $5,000.00 for

filing a false affidavit . . . ” and jointly sanctioned Dory Goebel and Option $5,000 for failing to

appear at the June 26th hearing. Id.

6. Second, the bankruptcy court sua sponte entered an additional Order to Show

Cause directing that a representative of Fidelity also appear on August 21, 2008 to explain the

amounts due on the mortgage loan of the debtors.3 [Docket No. 45].

7. At the conclusion of an evidentiary hearing on August 21, 2008, during which the

United States Trustee appeared and examined witnesses, the Court expanded the show cause

proceedings (Aug. 21, 2008 Transcript 268:19-20) and authorized the United States Trustee to

conduct discovery. See Mem. to Record August 21, 2008, Docket No. 70; Aug. 21, 2008

Transcript 208-09, 264, and 268-69.

8. On October 1, 2008, the United States Trustee issued written discovery requests to

Fidelity, Option and an attorney, D. Clay Wirtz. On October 2, 2008, the United States Trustee

issued a subpoena duces tecum to The Boles Law Firm (“Boles”).

9. Fidelity, Boles, and Option each filed motions to quash the United States

Trustee’s discovery requests. [Docket Nos. 76, 79 & 80]. The United States Trustee objected to

those motions. [Docket Nos. 82, 87, 90]. The Court heard oral argument on November 21, 2008.

3
Fidelity moved to appear in the Debtors’ Chapter 13 case on July 9, 2008. [Docket No. 43]. The
bankruptcy court’s July 18, 2008 Order Authorizing Fidelity National Foreclosure Solutions to Appear and Be Heard
granted Fidelity’s July 9, 2008 motion and directed that a hearing to “address Fidelity’s action and process” would
be scheduled for August 21, 2008. [Docket No. 49].

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In re Wilson, 2009 WL 304672 at *2 (Bankr. E.D. La.). On February 6, 2009, the Court entered

an Order denying those motions. Id. at *1.

10. On February 16, 2009, Fidelity filed its Motion to Clarify [Docket No. 127],

pursuant to Fed. R. Civ. P. 42. After a hearing on March 26, 2009, the bankruptcy court entered

its order denying Fidelity’s Motion to Clarify. [Docket No. 143].

11. On April 6, 2009, Fidelity filed its Notice of Appeal [Docket No. 147] and Motion

for Leave to Appeal. [Docket No. 150].

ARGUMENT

A. Discovery Orders Are Interlocutory And Ordinarily Not Appealable.

12. Discovery orders are interlocutory and are ordinarily not appealable. See e,g,

Church of Scientology v. U.S., 506 U.S. 9, 18 n.11, 113 S.Ct. 447 (1992)(dictum); U.S. v. Ryan,

402 U.S. 530, 91 S.Ct. 1580 (1971) (federal grand jury subpoena); Cobbledick v. U.S., 309 U.S.

323, 60 S.Ct. 540 (1940) (federal grand jury subpoena). The Fifth Circuit has consistently ruled

in accord with this basic tenet. See, e.g., Piratello v. Philips Electronics North America Corp.,

360 F.3d 506, 508 (5th Cir. 2004) (discovery order in post-judgment proceedings); and A-Mark

Auction Galleries v. American Numismatic Assoc., 233 F.3d 895, 897 (5th Cir. 2000) (subpoena

duces tecum).

13. The common rationale for denying interlocutory appeals of discovery orders is

that appellate review of such issues results in piecemeal litigation unnecessarily wasting judicial

resources and likely grinding the underlying action to a halt. See Clark-Dietz & Assocs. -Eng'rs,

Inc. v. Basic Constr. Co., 702 F.2d 67, 69 (5 th Cir. 1983), In re Babcock & Wilcox Co. No. 00-

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1154, 2000 WL 823473, *1 (E.D. La. June 22, 2000); Saddle Creek Energy Development v.

Eagle Domestic Drilling Operations, No. 07-MC-217, 2007 WL 1702398 (S.D. Tex. June 12,

2007) citing In re Global Marine, Inc., 108 B.R. 1007, 1009 (S.D. Tex 1988). Moreover, in the

context of discovery orders, appellate review is available from a final order of contempt. “[I]n

the rare case when appeal after final judgment will not cure an erroneous discovery order, a party

may defy the order, permit a contempt citation to be entered against him, and challenge the order

on direct appeal of the contempt citation.” Firestone Tire & Rubber Co. v. Risjord, 449 U.S. 368,

377, 101 S.Ct. 669, 675 (1981) (dicta); and Piratello, 360 F.3d at 508.

14. The United States Trustee has not yet filed a motion to compel discovery

responses or made any request that Fidelity be held in contempt. Thus, the bankruptcy court has

not ruled on a motion for contempt. Rather, the bankruptcy court has expressed that it would

continue to entertain requests with respect to individual issues of privilege or trade secrets in

connection with responding to the United States Trustee’s discovery requests.4

15. The Court should deny Fidelity’s Motion for Leave. That would provide two

options to Fidelity. It can comply with the discovery requests. Alternatively, it can refuse to

comply and appeal the Order in the context of a subsequent civil contempt order.

B. The District Court Should Exercise its Discretion and Deny Fidelity’s Motion for
Leave to Appeal.

1. There is No Mandated Standard for the District Court to Hear 28 U.S.C.

§158(a) Appeals.

4
“[I]f you believe that you need a protective order on a specific item that’s proprietary or privileged, I’ll
hear that at the time . . . .” March 26, 2009 Transcript, 74:17-19.

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16. Section 158(a) of title 28 authorizes a district court to grant leave to appeal an

interlocutory order from a bankruptcy court, but does not provide any standard for determining

whether to grant leave to appeal. Ichinose v. Homer National Bank (Matter of Ichinose), 946

F.2d 1169, 1177 (5th Cir. 1991). In every case, the decision to grant or deny leave to appeal a

bankruptcy court’s interlocutory order is committed to the district court’s discretion. Stumpf v.

McGee (In re O’Connor), 258 F.3d 392, 399-400 (5th Cir. 2001); In re Verges, 2007 WL 955042,

* 1 (E.D. La.).

17. The Fifth Circuit has observed that, in assessing whether to grant an interlocutory

appeal of a bankruptcy court order, many courts analogize to the standard under 28 U.S.C. §

1292(b). Ichinose, 946 F.2d 1177.5 The Fifth Circuit has not determined, however, whether such

analogy is the correct or mandated approach. See Ichinose, at 1177 (“We have not previously

considered whether it is proper for a district court to adopt the § 1292(b) standard for § 158(a)

purposes, and we do not do so here”).

18. The guiding principle for interlocutory bankruptcy appeals is that “[g]enerally, a

district court should grant leave sparingly, ‘since interlocutory bankruptcy appeals should be the

exception, rather than the rule.’” Wells Fargo Bank, N.A. v. Jones, 391 B.R. 577, 585 n. 24 (E.D.

La. 2008). Thus, motions for leave to appeal interlocutory orders should only be granted in

exceptional circumstances. See Escondido Mission Vill. L.P. v. Best Prod. Co., Inc. (In re

Escondido), 137 B.R. 114, 116 (S.D.N.Y. 1992) (to grant leave to appeal an interlocutory order,

5
See also In re Walker, No. 06-35035, 2007 W L 294157 at * 1 (S.D. Tex. January 29, 2007) (noting that
while the Fifth Circuit has not affirmatively decided the issue it has recognized that most courts apply the criteria set
forth in section 1292); Barkley v. U.S. ex rel U.S. Dep't of Treasury, No. Civ. A. 07-1631, 2007 W L 3445136 at *3
(W .D. La., Nov 13, 2007) (same).

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except in exceptional circumstances, “would contravene the well-established judicial policy of

discouraging interlocutory appeals and avoiding the delay and disruption which results from such

piecemeal litigation”) (internal citation omitted).

19. The determination whether such exceptional circumstances exist is a matter

within the sound discretion of the Court. See In re Sunflower Racing, Inc., 218 B.R. 972, 978

(D. Kan. 1998) (leave to appeal an interlocutory order should only be granted in exceptional

circumstances; the decision whether to grant leave is a matter “within the sound discretion of the

appellate court”); In re Stiles, 29 B.R. 389, 390 (M.D. Tenn. 1982) (“even where interlocutory

appeals may be granted, they are permissible only in exceptional or extraordinary situations”).

The burden is on Fidelity to demonstrate such exceptional circumstances. In re Countrywide

Home Loans, Inc., No. 08-617, 2008 WL 2388285 *5 (W.D. Pa. June 11, 2008) (“Countrywide,

as the party seeking an interlocutory appeal, bears the burden of demonstrating exceptional

circumstances”) (citation omitted).

20. The Court should exercise its discretion to deny the Motion for Leave because

Fidelity has failed to establish any exceptional circumstances justifying departure from the well

founded principles disfavoring interlocutory appeals. Denying the Motion for Leave will not

deprive Fidelity of a remedy and comports with the principles discouraging piecemeal appeals.

2. Even Under The § 1292(b) Factors, the Court Should Deny Fidelity’s
Request for Leave to Appeal.

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21. If the Court considers the § 1292(b) factors in deciding whether to grant Fidelity

leave to appeal,6 the Court should consider whether: (1) the issue involves a controlling question

of law; (2) the question is one where there is substantial ground for difference of opinion; and (3)

the question is such that an immediate appeal would advance the ultimate termination of the

litigation. Ichnose, 946 F.2d at 1177. Under those standards, the District Court should deny the

Motion for Leave.

22. The Section 1292(b) factors must be examined through the lens that interlocutory

appeals are generally “disfavored because they ‘interfere with the overriding goal of the

bankruptcy system, expeditious resolution of pressing economic difficulties.’” DuPree v. Kaye,

No. 3:07-CV-0768-B, 2008 WL 294532 at *2 (N.D. Tex. February 4, 2008) (internal citations

omitted); Chambers v. First United Bank & Trust Co., No. 4:08-mc-007, 2008 WL 5141264 at

*1 (E.D. Tex. December 5, 2008) (“Courts also have generally been inclined to deny leave to

appeal interlocutory orders of the bankruptcy court in the interest of promoting efficient

administration of the estate.”).

23. Moreover, the § 1292(b) criteria “are conjunctive, not disjunctive.” Ahrenholz v.

Board of Trustees of University of Illinois, 219 F.3d 674, 676 (7th Cir. 2000) (cited approvingly

on other grounds, Marlbrough v. Crown Equipment Corp., 392 F.3d 135, 136 (5th Cir. 2004));

Warner v. Unsecured Creditors Committee (In re Warner), 94 B.R. 734, 739 (M.D. Fla. 1988)

(“criteria listed in 28 U.S.C. § 1292(b) are conjunctive”; district court dismissing appeal due to

absence of all § 1292(b) factors); and Northwest Airlines, Inc. v. City of Los Angeles, No. 05-

6
Notwithstanding any of the specific § 1292(b) factors, the Court has the discretion to deny the Motion for
Leave.

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17930, 2008 WL 4755377, * 6 (S.D.N.Y. October 28, 2008) (“criteria for certifying a question

under § 1292(b) ‘are conjunctive, not disjunctive’”). Thus, the failure to demonstrate any of the

three factors dooms the requested appeal.

a. There is No Controlling Question Of Law.

24. Fidelity must establish that the Order implicates a “controlling” question of law.

An appropriate question would be “a pure question of law, something the court of appeals could

decide quickly and cleanly without having to study the record.” Ahrenholz v. Board of Trustees

of University of Illinois, 219 F.3d 674, 677 (7th Cir. 2000) (denying leave for interlocutory

appeal as not presenting “controlling question of law”). This contrasts with “a question of fact or

matter for the discretion of the trial court,” which would be an inappropriate question for the

district court to take on interlocutory appeal. See Garner v. Wolfinbarger, 430 F.2d 1093, 1097

(5th Cir. 1970) (finding question of corporate claim of privilege against its own shareholders an

appropriate question of law).

25. “In general, discovery orders do not present ‘controlling questions of law’ capable

of significantly advancing litigation so as to justify interlocutory appeal.” Stone Container Corp.

v. Owens-Illinois, Inc., 528 F.Supp. 794, 796 (N.D. Ga. 1981)(declining certification under §

1292(b)).

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26. Fidelity indicates that the controlling question of law concerns the bankruptcy

court’s reliance on 11 U.S.C. § 105(a):7

The Bankruptcy Court erred as a matter of law in concluding that it had authority
under Section 105(a) of the Bankruptcy Code to effectively rewrite the Federal
Rules of Civil Procedure which do not authorize a non-party, like the U.S.
Trustee, to serve discovery requests.

Fidelity Motion for Leave, ¶ 23.

27. The United States Trustee has consistently asserted that regardless of the Court’s

power under § 105(a), Fed. R. Bankr. P. 9014 provides direct authority for the issuance of the

discovery in the show cause proceeding. See, e.g, In re Count Liberty, LLC, 370 B.R. 259, 271

(Bankr. C.D. Cal. 2007) (amended show cause proceeding is a “contested matter”); In re Corella,

No. 4-06-00864-EWH, 2008 WL 704313, *2 (Bankr. D. Ariz. March 14, 2008) (a petition for

rule to show cause commenced a contested matter under Bankruptcy Rule 9014). While the

bankruptcy court cited § 105(a) in authorizing the United States Trustee’s issuance of formal

discovery, it did not expressly accept or reject the United States Trustee’s contention under Fed.

R. Bankr. P. 9014.8

7
Fidelity also cites the bankruptcy court’s “reliance on Bankruptcy Rule 2004 to empower the U.S.
Trustee to Propound discovery” as misplaced and thus another controlling question of law. Motion to Leave, p. 13.
The Reasons Opinion analogizes the posited formal discovery to that available under Rule 2004. The bankruptcy
court’s reliance on Rule 2004 cannot be a controlling question of law, though. That is so because the United States
Trustee did not move for authorization to conduct discovery under Rule 2004. Stated differently, had the United
States Trustee filed a motion for authority under Rule 2004, the bankruptcy court’s interpretation of Rule 2004
would be critical to whatever ruling it made. But the United States Trustee did not file such motion. Thus, the
bankruptcy court’s analogy or reference to Rule 2004 is not “controlling.” Even if the bankruptcy court’s reference
to Rule 2004 were found central to its ruling, issues concerning the scope of discovery under Rule 2004 “are left to
the sound discretion of the court that is fully familiar with the entire proceeding - the bankruptcy judge . . . .”
Hoffenberg v. Cohen (In re Towers Fin. Corp.), 164 B.R. 719, 720 (S.D.N.Y. 1994) (dismissing appeal of order
denying motion for examination under Rule 2004).

8
The bankruptcy court, though did question one component of the United States Trustee’s argument, that
the United States Trustee is a “party,” able to issue discovery under the formal discovery rules, Fed. R. Civ. P. 26-37

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b. The Litigation Would Only be Lengthened by an Interlocutory Appeal.

28. If this Court allows Fidelity’s appeal and eventually reverses the bankruptcy

court’s Order, it will lengthen, not shorten, the ultimate termination of the litigation.

29. The bankruptcy court could sua sponte require Fidelity to produce the same

documents and witnesses that the United States Trustee has sought through discovery. See July

11, 2008 Order, Docket No. 45, compelling attendance of a representative Fidelity to appear and

testify; and transcript of March 26, 2009 hearing on Fidelity’s Motion to Clarify, 15:7-14.9 It was

the bankruptcy court that sua sponte initiated the show-cause proceedings. Prior to the United

States Trustee’s issuing discovery, the bankruptcy court determined that certain testimony in the

show-cause proceeding was conflicting and necessary information was missing. August 21, 2008

Transcript 264:13 - 267:17.

30. Indeed, at the March 26, 2009 hearing the bankruptcy court indicated that if the

United States Trustee’s discovery was terminated, it would not end the court’s investigation.10

The court described a scenario wherein the court itself could require production of the same

documents and testimony from the same witnesses as requested by the United States Trustee in

its discovery requests:

(made applicable in contested matters pursuant to Fed. R. Bankr. P. 9014 and 7026-7037).

9
Court: “It seems to me more expensive . . . for the Court to say, you know, I think the U.S. Trustee’s
Office has made a point. Fly all five people down here. It may take us two weeks, but we’ll put them on one at a
time and I will question them.”

10
The bankruptcy court gave no specific ruling on how its show-cause proceedings would continue after
resolution of any appeal to the District Court.

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I could in a sense conduct my own discovery, collect all those exhibits [the
documents subject to pending requests for production], start reading them saying, well,
you know, this document refers to something else. I’d like to see those papers as well.
And this could go on for six months, it could go on for a year, and you could come as
often as I ordered you to come and put as many people on the stand as I ordered you to
come until I was satisfied.

That is a very practical concern for me. . . . I am perfectly capable of questioning a

witness on the stand. It seemed to me that it was less burdensome, frankly, to your client
to conduct what I would call normal, civil discovery.

Transcript of March 26, 2009 Hearing on Post-Judgment Motions filed by Fidelity, Option, and

Boles, 15:24-16:11.

31. In sum, in light of the bankruptcy court’s power to sua sponte continue its

investigation without issuance of discovery by the United States Trustee, and in light of the

conflicting testimony and missing information that the bankruptcy court determined, reversal of

the discovery order will not terminate the collateral proceeding that the bankruptcy court is

conducting. Rather, disallowing the United States Trustee’s discovery will likely only serve to

lengthen that process.

WHEREFORE, the United States Trustee prays that the Court deny Fidelity’s Motion for

Leave to Appeal and grant such general relief to which the United States Trustee may be entitled.

Respectfully submitted,

R. MICHAEL BOLEN
United States Trustee
Region 5, Judicial Districts of
Louisiana and Mississippi

by: s/ Mary Langston

MARY LANGSTON (22818)
Assistant U.S. Trustee
400 Poydras Street, Suite 2110

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New Orleans, LA 70130

Telephone no. (504) 589-4018
Direct telephone no. (504) 589-4093
Facsimile no. (504) 589-4096

SEAN M. HAYNES (TN # 14881)

LR 11.2 Trial Attorney
Admitted pro hac vice
Office of United States Trustee
200 Jefferson Avenue, Suite 400
Memphis, TN 38103
Telephone no. (901) 544-3251
Direct telephone no. (901) 544-3486
Facsimile no. (901) 544-4138

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