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SLATKIN & REYNOLDS, P.A.

One East Broward Boulevard, Suite 609, Fort Lauderdale, Florida 33301 Telephone 954.745.5880

UNITED STATES BANKRUPTCY COURT

SOUTHERN DISTRICT OF FLORIDA

WEST PALM BEACH DIVISION

www.flsb.uscourts.gov

In re:

MERIDIAN MARINA & YACHT CLUB

OF PALM CITY, LLC,

 Debtor.

CASE NO. 19-18585-MAM

CHAPTER 11

ZIMMER CONSTRUCTION CONSULTANTS, P.A.’S OBJECTION TO PLAN

Zimmer Construction Consultants, P.A. (“Zimmer”), by and through undersigned 

counsel, objects to the Second Amended Plan of Reorganization for Meridian Marina & Yacht 

Club of Palm City, LLC (the “Plan”) [ECF 140], and states as follows:

1. Zimmer filed Claim No. 13-1 in the amount of $14,229.96. The Claim was filed 

as secured as Zimmer recorded a claim of lien for the amounts owed to it.

2. The time for the Debtor to object to claims has passed. The Debtor did not file an 

objection to Zimmer’s Claim.

3. Notwithstanding that Zimmer filed a secured claim, the Debtor failed to treat 

Zimmer as secured and failed to include Zimmer in a class of secured claims, either on its own, 

or as part of another secured class.

4. The Debtor’s Plan therefore improperly classifies Zimmer and must be either 

amended or modified in order to properly treat Zimmer’s secured claim. 

5. Assuming that the Debtor reclassifies Zimmer as a secured claim, Zimmer has no 

other objections to the Plan. Zimmer would therefore request the Court sustain this Objection, 

require the Debtor to amend and/or modify the Plan in order to properly treat Zimmer’s Claim as 

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Case No. 20-12883-SMG

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SLATKIN & REYNOLDS, P.A.

One East Broward Boulevard, Suite 609, Fort Lauderdale, Florida 33301 Telephone 954.745.5880

secured and, assuming the Court confirms the Plan, require that Zimmer be paid as a secured 

claimant out of the sale of the property that the Plan contemplates.

WHEREFORE, for the reasons stated herein, Zimmer respectfully requests the Court 

sustain this Objection, require the Debtor to treat Claim No. 13-1 as a secured claim, require the 

Debtor to modify and/or amend the Plan such that Zimmer’s claim is treated as secured and paid 

out of the sale of the property contemplated in the Plan, as well as grant any further relief the 

Court deems proper under the circumstances.

Dated this 8th day of September, 2020.

SLATKIN & REYNOLDS, P.A.

Attorneys for Zimmer Construction

One East Broward Boulevard, Suite 609

Fort Lauderdale, Florida 33301

Telephone 954.745.5880

Facsimile 954.745.5890

rreynolds@slatkinreynolds.com

By: /s/ Robert F. Reynolds

 ROBERT F. REYNOLDS

 Fla. Bar No. 174823

CERTIFICATE OF SERVICE

I hereby certify that a true copy of the foregoing has been furnished via the Court’s 

CM/ECF electronic noticing system to Heidi A. Feinman, Trustee, heidi.a.feinman@usdoj.gov; 

Dana L. Kaplan, Esq., dana@kelleylawoffice.com, tina@kelleylawoffice.com; Craig I. Kelley, 

Esq., craig@kelleylawoffice.com, dana@kelleylawoffice.com; Susan D. Lasky, Esq., 

ecf@suelasky.com, ecfsuelasky@gmail.com; Alan B. Rose, Esq., arose@mrachek-law.com, 

manderson@mrachek-law.com; Craig I. Kelley, Esq., craig@kelleylawoffice.com; Office of the 

US Trustee, USTPRegion21.MM.ECF@usdoj.gov on this 8th day of September, 2020.

 /s/ Robert F. Reynolds

 ROBERT F. REYNOLDS

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