UNITED STATES BANKRUPTCY COURT 

SOUTHERN DISTRICT OF FLORIDA 

MIAMI DIVISION 

www.flsb.uscourts.gov

In re: Chapter 11 

AMERICA-CV STATION GROUP, INC., Case No. 19-16355-BKC-AJC 

 

 Debtor. 

______________________________/ 

In re: Chapter 11 

CARIBEVISION HOLDINGS, INC., Case No. 19-16359-BKC-AJC 

 

 Debtor. 

______________________________/ 

In re: Chapter 11 

AMERICA-CV NETWORK, LLC, Case No. 19-16976-BKC-AJC 

 

 Debtor. 

______________________________/ 

In re: Chapter 11 

CARIBEVISION TV NETWORK, LLC, Case No. 19-16977-BKC-AJC 

 

 Debtor. 

______________________________/ 

EX-PARTE MOTION BY CHAPTER 11 

DEBTORS FOR JOINT ADMINISTRATION OF CASES 

AMERICA-CV STATION GROUP, INC., CARIBEVISION HOLDINGS, INC., 

AMERICA-CV NETWORK, LLC and CARIBEVISION TV NETWORK, LLC (collectively, 

the “Debtors”), by and through counsel, and pursuant to Fed. R. Bankr. P. 1015(b) and Local 

Rule 1015-1(B), hereby file this Ex-Parte Motion By Chapter 11 Debtors for Joint 

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Administration of Cases (the “Motion”). In further support of this Motion, the Debtors 

respectfully represent as follows: 

Jurisdiction and Background 

1. The Court has jurisdiction over this Motion pursuant to 28 U.S.C. §§ 157 and 

1334. This matter is a core proceeding pursuant to 28 U.S.C. § 157(b)(2). Venue of this 

proceeding is proper in this district and before this Court pursuant to 28 U.S.C. §§ 1408 and 

1409. 

2. On May 14, 2019, AMERICA-CV STATION GROUP, INC., CARIBEVISION 

HOLDINGS, INC. and on May 28, 2019, AMERICA-CV NETWORK, LLC and 

CARIBEVISION TV NETWORK, LLC (respectively and collectively, the “Petition Date”), 

each filed a voluntary petition in this Court for relief under Chapter 11 of Title 11 of the United 

States Code (the “Bankruptcy Code”). Since that time, the Debtors have operated as debtors-inpossession pursuant to Sections 1107 and 1108 of the Bankruptcy Code. 

3. CARIBEVISION HOLDINGS, INC. is the parent company for AMERICA-CV 

STATION GROUP, INC. CARIBEVISION TV NETWORK, LLC is the parent company of 

AMERICA CV NETWORK, LLC. Parent companies CARIBEVISION HOLDINGS, INC. and 

CARIBEVISION TV NETWORK, LLC have common ownership of Vasallo TV Group, LLC 

(16.6% of Caribevision Holdings, Inc. and 16.6% of Caribevision TV Network, LLC) and 

Pegaso Television Corp. (10.5% of Caribevision Holdings, Inc. and 83.4% of Caribevision TV 

Network, LLC). As such, the Debtors are “affiliates” as that term is defined in Section 101(2) of 

the Bankruptcy Code and as used in Bankruptcy Rule 1015(b). 

4. The Debtors have interrelated liabilities, management, contractual arrangements 

and operations, including but not limited to operating from the same corporate headquarters at 

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13001 NW 107th Ave., Hialeah Gardens, FL 33018. 

5. Given the affiliation of the Debtors and, more significantly, the common interests 

of the Debtors with respect to the reorganization of the Debtors’ estates, joint administration of 

these Chapter 11 cases before Judge A. Jay Cristol under the case In re America-CV Station 

Group, Inc. Case No.: 19-16355-BKC-AJC (the “Lead Case”) shall, among other things: (i) 

preserve judicial resources and consistency of rulings that may impact on the Debtors and 

creditors of the estates; and (ii) avoid duplicity of pleadings, motions and other court papers filed 

during the proceedings. 

6. The proposed caption for the jointly administered cases is 

UNITED STATES BANKRUPTCY COURT 

SOUTHERN DISTRICT OF FLORIDA 

Miami Division 

In re: 

 Chapter 11 

AMERICA-CV STATION GROUP, INC, Case No. 19-16355-BKC-AJC 

CARIBEVISION HOLDINGS, INC., Case No. 19-16359-BKC-AJC 

AMERICA-CV NETWORK, LLC, Case No. 19-16976-BKC-AJC 

CARIBEVISION TV NETWORK, LLC, Case No. 19-16977-BKC-AJC

 

 Debtors. (Jointly Administered Under Case 

 No. 19-16355-BKC-AJC) 

____________________________________/ 

7. Moreover, joint administration of the Debtors’ Chapter 11 cases will protect both 

the Debtors and creditors against any conflict of interest between the estates. 

8. For these reasons, the Debtors respectfully request that the Bankruptcy Court 

enter an order pursuant to Bankruptcy Rule 1015 for joint administration of these cases before 

Judge A. Jay Cristol under the Lead Case. 

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9. A proposed Order granting this Motion is attached hereto and has been uploaded 

to the Court in each of the Debtors’ cases via CM/ECF. 

WHEREFORE, the Chapter 11 Debtors, AMERICA-CV STATION GROUP, INC., 

CARIBEVISION HOLDINGS, INC., AMERICA-CV NETWORK, LLC and CARIBEVISION 

TV NETWORK, LLC, respectfully request that the Court enter an Order (i) directing the joint 

administration of the Debtors’ estates under the Lead Case in accordance with the Local Rules of 

the U.S. Bankruptcy Court for the Southern District of District of Florida; and (ii) granting such 

other and further relief as the Court deems appropriate. 

Dated: May 28, 2019. 

 Respectfully Submitted, 

GENOVESE JOBLOVE & BATTISTA, P.A. 

 Proposed Attorneys for Debtors-in-Possession 

 100 SE 2nd Street, 44th Floor 

 Miami, FL 33131 

 Telephone: (305) 349-2300 

 Facsimile : (305) 349-2310 

 By: /s/ Heather L. Harmon 

 Paul J. Battista, Esq. 

Florida Bar No. 884162 

pbattista@gjb-law.com

Heather L. Harmon, Esq. 

Fla. Bar No. 013192 

hharmon@gjb-law.com

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