UNITED STATES BANKRUPTCY COURT

SOUTHERN DISTRICT OF FLORIDA

WEST PALM BEACH DIVISION

www.flsb.uscourts.gov

IN RE: CASE NO.: 19-18585-MAM

Chapter 11

MERIDIAN MARINA & YACHT CLUB 

OF PALM CITY, LLC

Debtor. 

______________________________/

MERIDIAN MARINA & YACHT CLUB OF PALM CITY, LLC’S 

OBJECTION TO CLAIM OF BARTLETT BROTHERS SECURITY

(SCHEDULED CLAIM; NO PROOF OF CLAIM FILED)

IMPORTANT NOTICE TO CREDITOR:

THIS IS AN OBJECTION TO YOUR CLAIM

This objection seeks either to disallow or reduce the amount or change the 

priority status of the claim filed by you or on your behalf. Please read this objection 

carefully to identify which claim is objected to and what disposition of your claim 

is recommended.

If you disagree with the objection or the recommended treatment, you must 

file a written response WITHIN 30 DAYS from the date of service of this objection, 

explaining why your claim should be allowed as presently filed, and you must serve 

a copy to the undersigned attorney OR YOUR CLAIM MAY BE DISPOSED OF IN 

ACCORDANCE WITH THE RECOMMENDATION IN THIS OBJECTION.

If your entire claim is objected to and this is a chapter 11 case, you will not

have the right to vote to accept or reject any proposed plan of reorganization until 

the objection is resolved, unless you request an order pursuant to Bankruptcy Rule 

3018(a) temporarily allowing your claim for voting purposes.

The written response must contain the case name, case number, and must 

be filed with the Clerk of the United States Bankruptcy Court.

Pursuant to Bankruptcy Rule 3007 and Local Rule 3007-1, the debtor(s) object(s) 

to the following claim(s) filed in this case and on the grounds set forth therein. Accordingly, 

the claim(s) should be stricken and disallowed.

Case 19-18585-MAM Doc 280 Filed 10/29/20 Page 1 of 3
Name of Claimant

Claim 

Amount

Claim 

Number

Basis for Objection and 

Recommended Disposition

BARTLETT 

BROTHERS 

SECURITY

$190.80

Scheduled 

Claim; No 

Proof of 

Claim filed

Objection – Claim has been paid 

pre-petition. Claim shall be stricken

WHEREFORE, the Debtor respectfully request this Court enter an order sustaining 

this Objection, disallowing the Claims listed above, and granting such other and further 

relief as may be just. 

I HEREBY CERTIFY that I am admitted to the Bar of the United States District 

Court for the Southern District of Florida and I am in compliance with the additional 

qualifications to practice in this court set forth in Local Rule 2090-1(A) and that a true and 

correct copy of the foregoing was furnished via U.S. Mail to the parties listed on the 

attached mail list this 30th day of October, 2020.

KELLEY, FULTON & KAPLAN, P.L.

Attorneys for the Debtors in Possession

1665 Palm Beach Lakes Blvd., Ste 1000

West Palm Beach, FL 33401

Phone (561) 491-1200

Facsimile (561) 684-3773

By: /s/ Dana Kaplan, Esq.

 DANA KAPLAN, ESQUIRE

 Florida Bar 44315

Mailing Information for Case 19-18585-MAM

Electronic Mail Notice List

The following is the list of parties who are currently on the list to receive email 

notice/service for this case.

Case 19-18585-MAM Doc 280 Filed 10/29/20 Page 2 of 3
• John P Carrigan jpc@reblawpa.com, mmj@reblawpa.com

• Amber E Donner Amber.Donner@SpectorRubin.com, 

heidiparalegal@gmail.com

• Heidi A Feinman Heidi.A.Feinman@usdoj.gov

• Linda W Jackson LJackson@PardoJackson.com, 

catheryne@pardojackson.com;mfuentes@pardojackson.com

• Dana L Kaplan dana@kelleylawoffice.com, 

tina@kelleylawoffice.com;cassandra@kelleylawoffice.com;kristina@kelleylawoffi

ce.com;debbie@kelleylawoffice.com;craig@kelleylawoffice.com

• Craig I Kelley craig@kelleylawoffice.com, 

tina@kelleylawoffice.com;cassandra@kelleylawoffice.com;kristina@kelleylawoffi

ce.com;debbie@kelleylawoffice.com;dana@kelleylawoffice.com

• Office of the US Trustee USTPRegion21.MM.ECF@usdoj.gov

• Alan B Rose arose@mrachek-law.com, manderson@mrachek-law.com

Manual Notice List

The following is the list of parties who are not on the list to receive email notice/service 

for this case (who therefore require manual noticing/service). 

Aspen Environmental Consulting, LLC

2014 SW Oxbow Way

Palm City, FL 34990

Charles Goodman

3022 SW Lake Terrace

Palm City, FL 34990

Stetson Insurance Funding

6450 Transit Road

Depew, 14043

BARTLETT BROTHERS SECURITY

2694 SE Willoughby Blvd.

Stuart, FL 34994

Case 19-18585-MAM Doc 280 Filed 10/29/20 Page 3 of 3