Rule 9006 Creates Trap for Date-Specific Deadlines

A debtor was liberated from an objection to discharge where the deadline was extended to January 15, 2018, which was Martin Luther King, Jr. Day and the objection was not filed until the next day.    Smart-Fill Management Group, Inc. v. Froiland (In re Froiland), 18-1006 (Bankr. W.D. Tex. 7/6/18).    While most practitioners are familiar with the rule which extends deadlines that fall on a Saturday, Sunday or national holiday, there is an important caveat:  the rule only applies to deadlines stated in days or a longer unit of time.   Where a deadline is set for a date certain, there is no extension.