UNITED STATES BANKRUPTCY COURT 

FOR THE SOUTHERN DISTRICT OF FLORIDA 

Miami Division 

www.flsb.uscourts.gov

In re: 

PAUL WIGODA, 

 Debtor. 

______________________________________/

 Case No. 19-22567-AJC 

 Chapter 11 

PW CAPITAL COLLECTIONS, LLC’S 

OBJECTION TO DEBTOR’S CLAIM OF EXEMPTIONS 

 Pursuant to Federal Rule of Bankruptcy Procedure 4003 and 11 U.S.C. § 522, PW Capital 

Collections, LLC (“PW Capital”) objects to Debtor Paul Wigoda’s claim of exemptions in his 

amended Schedule C [ECF #86]. The grounds for this objection are as follows. 

Background 

1. The Debtor filed this chapter 11 case on September 20, 2019 [ECF #1]. 

2. The Debtor filed his initial schedules on October 11, 2019 [ECF #30]. 

3. The chapter 11 trustee held and concluded the Debtor’s section 341 meeting of 

creditors on October 22, 2019 [ECF #4]. The filing deadline for objections to the Debtor’s claimed 

exemptions was 30 days after the conclusion of the meeting of creditors. 

4. PW Capital timely filed an objection on November 20, 2019 [ECF #50]. 

5. Pursuant to an agreement between PW Capital and the Debtor, the Court rolled over 

the hearing on the objection to allow the Debtor to amend his Schedule C [ECF #63]. 

6. On January 8, 2020, the Debtor filed his amended Schedule C [ECF #86]. 

Objection 

The Debtor has claimed his homestead real property as exempt pursuant to sections 222.01 

and 222.02 of the Florida Statutes and article X, section 4(a)(1) of the Florida Constitution. Thus, 

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pursuant to Florida law, the Debtor is entitled to exempt personal property having a value of up to 

$1,000.00. The Debtor claimed $700.00 of the $1,000.00 exemption for a portion of his “household 

furniture” listed with a total value of $10,000.00, and the remaining $300.00 of the exemption for 

his interests in three entities with “unknown” values: PPGW Limited Partnership (listed twice); 

PW Family Limited Partnership; and PW Management Co. 

PW Capital objects to any and all personal property claimed as exempt by the Debtor that 

exceeds the $1,000.00 amount permitted by Florida law. 

PW Capital further objects to the values of the property claimed as exempt, including, but 

not limited to, the household furniture and the Debtor’s interests in the three entities. 

WHEREFORE, PW Capital respectfully requests that the Court enter an order sustaining 

PW Capital’s objection to the Debtor’s claim of exemptions and the values of the property claimed 

as exempt, and granting such further relief as is just and appropriate. 

I hereby certify that I am admitted to the Bar of the United States District Court for the Southern 

District of Florida and that I am in compliance with the additional qualifications to practice in 

this Court set forth in Local Rule 2090-1(A). 

Respectfully submitted, 

WEISSMAN & DERVISHI, P.A. 

 

By: /s/ Peter A. Tappert

 Brian S. Dervishi 

Peter A. Tappert 

 Fla. Bar Nos. 350303 and 27100 

 SunTrust International Center 

 One Southeast Third Avenue, Suite 1700 

 Miami, Florida 33131 

 305-347-4070 (Telephone) 

 305-347-4077 (Facsimile) 

 bdervishi@wdpalaw.com

ptappert@wdpalaw.com 

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SEQUOR LAW, P.A. 

 

By: /s/ Gregory S. Grossman 

 Gregory S. Grossman 

 Fla. Bar No. 896667 

 1001 Brickell Bay Dr., 9th Floor 

 Miami, Florida 33131 

 305-372-8282 (Telephone) 

 305-372-8202 (Facsimile) 

 ggrossman@sequorlaw.com

 Attorneys for PW Capital Collections, LLC 

CERTIFICATE OF SERVICE 

I HEREBY CERTIFY that on February 7, 2020, a true and correct copy of the foregoing 

was served by CM/ECF on the parties named below and all others entitled to receive notice. 

 /s/ Peter A. Tappert

 Peter A. Tappert 

Bradley S. Shraiberg, Esq. 

Shraiberg Landau & Page, P.A. 

2385 NW Executive Center Dr., Suite 300 

Boca Raton, FL 33431 

U.S. Trustee 

Office of the U.S. Trustee 

51 S.W. 1st Ave., Suite 1204 

Miami, FL 33130 

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