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 PROGRESSIVE ENVIRONMENTAL SERVICES INC.

(CLAIM NO. 11)

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 290 Filed 10/29/20 Page 1 of 3
Name of Claimant

Claim 

Amount

Claim 

Number

Basis for Objection and 

Recommended Disposition

PROGRESSIVE 

ENVIRONMENTAL 

SERVICES INC.

$58,433.21 Claim No. 

11

Objection – The correct amount of 

this claim is $46,179.83. Claim 

shall be reduced to $46,179.83.

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 29th 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 290 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

PROGRESSIVE ENVIRONMENTAL SERVICES INC.

Jonathan Selden

19 National Drive

Franklin, MA 02038

Case 19-18585-MAM Doc 290 Filed 10/29/20 Page 3 of 3