UNITED STATES BANKRUPTCY COURT 

SOUTHERN DISTRICT OF FLORIDA 

MIAMI DIVISION 

www.flsb.uscourts.gov

IN RE: Case No. 19-22567-AJC

Paul Wigoda Chapter 11

Debtor. 

RESPONSE TO DEBTOR’S EXPEDITED MOTION 

TO SELL FT. LAUDERDALE REAL PROPERTY 

Comes now, Secured Creditor, JP Morgan Chase Bank, National Association by and through 

its undersigned attorney and hereby files its response to Debtor’s expedited motion to sell Ft. 

Lauderdale Property (Doc. No. 347) and states as follows: 

1. On September 20, 2019 Debtor filed this voluntary petition under Chapter 11 of the 

Bankruptcy Code. 

2. On July 20, 2021 Debtor filed an expedited motion to sell Ft. Lauderdale Property 

located at 2600 Northeast 30th Street, Ft Lauderdale, FL 33306 which is the subject real property. 

3. On November 15, 2019 JP Morgan Chase Bank, National Association filed Claim 7-

1 which listed a total secured claim of $425,288.70 a +secured arrearages of $32,255.45, and 

regular monthly payments of $4,469.17 for a mortgage encumbering real property located at 2600 

Northeast 30th Street, Ft Lauderdale, FL 33306. 

4. On October 6, 2020 Debtor filed its Amended Chapter 11 Plan of Reorganization. 

The Amended Chapter 11 Plan of Reorganization provided for the Debtor to attempt to sell the 

subject property and related JP Morgan Chase Bank, National Association mortgage interest 

(referred to as class 4) within six months of the effective date of the chapter 11 plan of 

reorganization. See Doc. No. 243. 

Case 19-22567-AJC Doc 354 Filed 07/26/21 Page 1 of 4
5. On February 16, 2021 this Court Ordered Confirmation of the Amended Chapter 

11 Plan of Reorganization. See Doc. No. 339. 

6. Although JP Morgan Chase Bank, National Association does not oppose a sale of 

the property located at 2600 Northeast 30th Street, Ft. Lauderdale, FL 33306, Movant would 

require the Order to include language that JP Morgan Chase, National Association Claim, and 

related class 4 plan treatment will be paid in full for the subject mortgage from the closing proceeds 

as soon as practicable following this Court’s approval of the sale. 

Wherefore, JP Morgan Chase Bank, National Association requests this Court grant Debtor’s 

Expedited Motion to Sell Ft. Lauderdale Property and include language in the Order approving the 

sale that JP Morgan Chase Bank, National Association, will be paid-in-full from the closing sale 

proceeds as soon as practicable by the title company following this Court’s approval of the 

anticipated sale. 

/s/Steven G. Powrozek 

Steven G. Powrozek 

FL Bar 0316120 

Elizabeth Eckhart 

FL Bar 48958 

LOGS Legal Group LLP 

Attorney for Secured Creditor 

4630 Woodland Corporate Boulevard 

Suite 100 

Tampa, FL 33614 

Telephone: (813) 880-8888 

Fax: (813) 880-8800 

E-mail: logsecf@logs.com

CERTIFICATE OF SERVICE 

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

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

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

Case 19-22567-AJC Doc 354 Filed 07/26/21 Page 2 of 4
The undersigned certifies that on this 22nd day of July, 2021, a copy of the foregoing 

response to expediated motion to sell real property was caused to be served via CM/ECF electronic 

filing or via First Class U.S. Mail upon the following: 

Paul Wigoda 

18201 Collins Ave, Apt 1709 

Sunny Isles Beach, FL 33160 

Joshua Lanphear 

Shraiberg, Landau & Page, P.A. 

2385 NW Executive Center Dr., #300 

Boca Raton, FL 33431 

Bradley S Shraiberg 

2385 NW Executive Center Dr. #300 

Boca Raton, FL 33431 

Office of the US Trustee 

51 S.W. 1st Ave. 

Suite 1204 

Miami, FL 33130 

Johanna Armengol 

Office of the US Trustee 

51 SW 1 Ave #1204 

Miami, FL 33130 

Steven D Schneiderman 

Office of the US Trustee 

51 SW 1 Ave #1204 

Miami, FL 33130 

/s/Steven G. Powrozek 

Steven G. Powrozek 

FL Bar 0316120 

Elizabeth Eckhart 

FL Bar 48958 

LOGS Legal Group LLP 

Attorney for Secured Creditor 

4630 Woodland Corporate Boulevard 

Suite 100 

Tampa, FL 33614 

Telephone: (813) 880-8888 

Case 19-22567-AJC Doc 354 Filed 07/26/21 Page 3 of 4
Fax: (813) 880-8800 

E-mail: logsecf@logs.com

19-321537 BK01 CHE

Case 19-22567-AJC Doc 354 Filed 07/26/21 Page 4 of 4