UNITED STATES BANKRUPTCY COURT 

SOUTHERN DISTRICT OF FLORIDA 

MIAMI DIVISION 

IN RE: 

CASE NO.: 19-21168-RAM 

Chapter: 13 

William David Sullivan, II, 

Debtor. 

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AGREED ORDER GRANTING SECURED CREDITOR’S, MIKON 

FINANCIAL SERVICES, INC., MOTION FOR PROSPECTIVE RELIEF FROM STAY 

THIS CASE came before the Court on October 22, 2019 at 9:00am, on Secured Creditor’s, 

MIKON FINANCIAL SERVICES, INC. (“CREDITOR”), Motion for Prospective Relief from Stay (Doc. 

26) (the “Motion”), and the Court having reviewed the Motion, the file, and being advised that 

CREDITOR and Debtor, WILLIAM DAVID SULLIVAN, II (“DEBTOR”), are in agreement, and being 

otherwise fully advised in the premises, it is hereby: 

ORDERED and ADJUDGED as follows: 

1. The Motion is GRANTED IN PART. 

ORDERED in the Southern District of Florida on October 23, 2019.

Robert A. Mark, Judge

United States Bankruptcy Court

_____________________________________________________________________________

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CASE NO.: 19-21168-RAM 

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2. The automatic stay imposed by the filing of the instant case on August 21, 2019 

has expired, as the DEBTOR did not timely file a motion to extend the stay. 

3. As such, there is no automatic stay currently in effect. 

4. Notwithstanding the foregoing, pursuant to the agreement of the CREDITOR and 

DEBTOR, the DEBTOR shall be permitted to continue with the instant Ch. 13 bankruptcy case;

CREDITOR agrees to have its claim treated through the Chapter 13 Plan and to stay any state 

court action to enforce its claim, as long as the instant case is not dismissed, or converted to a 

Chapter other than 13. 

5. However, in the event that the instant bankruptcy case is dismissed or is 

converted to a Chapter other than 13, then CREDITOR shall be deemed to have been granted 

prospective stay relief, for a period of 18 months from the entry of a dismissal or conversion 

order, so that CREDITOR may pursue its in rem remedies against the property currently owned 

by the DEBTOR located in Miami-Dade County, Florida and more particularly described as 

follows: 

LOT 5, BLOCK 1, OF WEST LITTLE RIVER ANNEX, ACCORDING TO 

THE PLAT THEREOF, AS RECORDED IN PLAT BOOK 40 PAGE 74, OF 

THE PUBLIC RECORDS OF MIAMI DADE COUNTY 

Parcel ID: 30-3111-003-0090 

Property address: 8240 NW 15th Avenue, Miami, FL 33147 (hereinafter the 

“Property”). 

6. The prospective stay relief granted by this Order is to CREDITOR as it relates to 

the Property, such that the prospective stay relief shall apply to all future bankruptcy cases filed 

by DEBTOR or any other person or entity claiming an interest in the Property, by, through, or 

under DEBTOR. 

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7. The filing of a future bankruptcy case by DEBTOR or any other person or entity 

claiming an interest in the Property by, through, or under DEBTOR, for a period of 18 months 

from the entry of a dismissal or conversion order of the instant case, shall not trigger the 

imposition of the automatic stay under 11 U.S.C. 362, and shall not serve to stop, cancel, or 

delay, the pursuit of in rem remedies under non-bankruptcy law, including but not limited to, a 

tax deed sale of the Property by CREDITOR, the Miami-Dade County Clerk of Courts, or their 

agents or assigns. 

8. The fourteen (14) day stay of this Order pursuant to Bankruptcy Rule 4001(a)(3) 

is waived. 

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ORDER SUBMITTED BY: 

Gregory R. Bel, Esq. 

GREGORY R. BEL, PLLC 

301 Alhambra Cir., Suite 1200 

Coral Gables, Florida 33134 

Telephone: (305) 448-7064 

gbel@grblegal.com

Gregory R. Bel, Esq. is directed to serve a conformed copy of this Order on all interested parties 

and to file with the Court a certificate of service conforming with Local Rule 2002-1(F). 

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