UNITED STATES BANKRUPTCY COURT 

SOUTHERN DISTRICT OF FLORIDA 

MIAMI DIVISION

www.flsb.uscourts.gov

IN RE: CASE NO.: 19-14839-AJC 

GOOD SHEPHERD CHURCH, INC. 

 Debtor./ 

Chapter 7 

TRUSTEE'S MOTION TO DISMISS CASE 

WITH A TWO-YEAR PREJUDICE PERIOD 

Ross Hartog, as Trustee for the estate of Good Shepherd Church, Inc. (the "Debtor"), by 

and through the undersigned counsel, moves for the entry of an order dismissing this case. In 

support of this motion (the “Motion”), the Trustee states as follows: 

1. On April 15, 2019 (the “Petition Date”), the Debtor filed a “skeleton” petition – 

without schedules or a statement of financial affairs - under chapter 7 of the Bankruptcy Code. 

2. The Debtor is not represented by an attorney. 

3. As of the filing of this Motion, the Debtor still has not filed its Schedules or 

Statement of Financial Affairs. 

4. Pursuant to Florida Division of Corporations, the Debtor was formed on August 30, 

2018. 

5. On November 6, 2018, a little over three months after the Debtor was formed, New 

Beginnings of South Florida, Inc. (“New Beginnings”) transferred (the “Transfer”) seventeen 

parcels of real property (the “Real Properties”) to the Debtor by quit claim deed recorded in MiamiDade County Official Records Book 31209, Pages 3188-3192. 

Case 19-14839-AJC Doc 69 Filed 07/26/19 Page 1 of 4
6. As was thoroughly discussed in previous hearings, New Beginnings filed four 

separate bankruptcy cases, which appeared to be attempts by New Beginnings to avoid foreclosure 

of the Real Properties. 1 

7. The Trustee suspects that the Transfer and the instant case was a continued effort 

to avoid foreclosure. 

8. However, obtaining the information to determine whether the Transfer was part of 

a greater scheme to avoid foreclosure has proved difficult given the Debtor’s lack of cooperation 

and failure to file schedules or a statement of financial affairs. 

9. It has only been in the past week that the Trustee and his counsel were able to have 

meaningful discussions with principals of the Debtor. 

10. Notwithstanding this fact, the Trustee believed and continues to believe that the 

Debtor is a “mere-continuation” of New Beginnings. 

11. And it was on this basis that the Trustee and certain creditors requested that the case 

not be immediately dismissed. 

12. Accordingly, the Trustee worked to administer certain of the Real Properties. 

13. Unfortunately, no unsecured creditors filed claims and it is not appropriate for a 

trustee to administer assets solely for the benefit of secured creditors. 

14. In light of the foregoing, the Trustee seeks an order dismissing this bankruptcy case 

and that the dismissal be "with prejudice" to the filing of any bankruptcy case in any federal 

bankruptcy court in the United States of America by the Debtor for two years from entry of this 

order. 

 

1

 On January 4, 2019, New Beginnings filed pro se, a skeleton petition for relief under Chapter 11, case no. 19-

10138-LMI (the “Fourth Bankruptcy”). After an evidentiary hearing on an Order to Show Cause, Judge Isicoff 

dismissed the Forth Bankruptcy with prejudice for three years. See ECF No. 38, Case no. 19-10138-LMI. 

Case 19-14839-AJC Doc 69 Filed 07/26/19 Page 2 of 4
WHEREFORE, the Trustee respectfully requests that this Court enter an order (a) granting 

the Motion, (b) dismissing this bankruptcy case, (c) declaring that the Debtor may not file another 

bankruptcy case in any federal bankruptcy court in the United States of America for two years 

from entry of this order; and (d) granting such other and further relief as the Court deems just and 

proper. 

CERTIFICATE OF SERVICE 

I HEREBY CERTIFY that a true and correct copy of the foregoing was served on all 

counsel of record or pro se parties identified on the attached Service List via the Court’s CM/ECF 

notification to those parties who are registered CM/ECF participants and/or U.S. Mail on July 26, 

2019. 

Dated: July 26, 2019 MARKOWITZ, RINGEL, TRUSTY & HARTOG, P.A. 

 Counsel for the Trustee 

9130 South Dadeland Boulevard 

 Two Datran Center, Suite 1225 

 Miami, Florida 33156-7849 

 Telephone: (305) 670-5000 

 By:/s/ John H. lee 

 John H. Lee 

 Fla. Bar No.: 91795 

 jlee@mrthlaw.com

 

Case 19-14839-AJC Doc 69 Filed 07/26/19 Page 3 of 4
In re: Good Shepherd Church, Inc. 

Case No. 19-14839-AJC 

Service List 

19-14839-AJC Notice will be electronically mailed to: 

Ross R Hartog 

rhartog@mrthlaw.com, FL81@ecfcbis.com; rhartog@ecf.epiqsystems.com; 

rrh@trustesolutions.net;rhartog@ecf.courtdrive.com 

John H Lee on behalf of Trustee Ross R Hartog 

jlee@mrthlaw.com, ecfnotices@mrthlaw.com, mrthbkc@gmail.com, jgarey@mrthlaw.com, 

ycandia@mrthlaw.com, gruiz@mrthlaw.com; 

markowitzjr73991@notify.bestcase.com,jlee@ecf.courtdrive.com 

Gary M Murphree on behalf of Creditor City First Mortgage Corp.

gmm@amlaw-miami.com, babreu@amlaw-miami.com;mramirez@amlawmiami.com;amlaw.bestcase@gmail.com;abreubr75008@notify.bestcase.com 

Office of the US Trustee 

USTPRegion21.MM.ECF@usdoj.gov 

John L Penson on behalf of Creditor ARCPE 2 LLC 

pensonservice@gmail.com, pensonservice@gmail.com,Barbara@pensonlaw.org 

19-14839-AJC Notice will be mailed to: 

Good Shepherd Church, Inc 

14500 NE 6th Ave 

North Miami, FL 33161 

Good Shepherd Church, Inc 

14500 NE 6th Ave, Unit B 

North Miami, FL 33161 

Miami Dade County Tax Collector (windley) 

200 NW 2nd Avenue, Suite 430 

Miami, FL 33128 

Barry Mukamal 

1000 South Federal Highway 

Suite 200 

Ft. Lauderdale, FL 33316 

Case 19-14839-AJC Doc 69 Filed 07/26/19 Page 4 of 4