UNITED STATES BANKRUPTCY COURT 

SOUTHERN DISTRICT OF FLORIDA 

MIAMI DIVISION 

www.flsb.uscourts.gov 

 

In re: CASE NO.: 18-19121-BKC-RAM 

1 GLOBAL CAPITAL LLC, et. al.,

1

 CHAPTER 11 

 (Jointly Administered) 

Debtors. 

 / 

 

RAPID FINANCIAL SERVICES, LLC, 

 

 Plaintiff, ADV. CASE NO.: 19-01636-RAM 

v. 

 

HILLSBOROUGH RIVER PHARMACY, INC., 

and AMBROSE CHUKWUEKE, 

 

 Defendants. 

 / 

JOINT STIPULATION OF DISMISSAL 

OF ADVERSARY PROCEEDING 

 Plaintiff, Rapid Financial Services, LLC (the “Plaintiff”), and Defendants, Hillsborough River 

Pharmacy, Inc. and Ambrose Chukwueke (the “Defendants”), pursuant to Rule 41(a)(1)(A)(ii) of the 

Federal Rules of Civil Procedure, as made applicable to this proceeding by Rule 7041 of the Federal 

Rules of Bankruptcy Procedure, stipulate to the dismissal of this proceeding, with each party bearing its 

own attorneys’ fees, costs, and expenses (the “Stipulation”). 

 Pursuant to this Stipulation, the referenced Parties request that the Court enter an order of 

1

 The Debtors in these Chapter 11 Cases, along with the business addresses and the last four (4) digits of each Debtor’s federal 

tax identification number, if applicable, are: 1 Global Capital LLC, d/b/a 1 GC Collections, c/o Development Specialists, 

Inc.: 500 West Cypress Creek Road, Suite 400, Fort Lauderdale, FL 33009 (9517); and 1 West Capital LLC, d/b/a 1 West 

Collections, c/o Development Specialists, Inc.: 500 West Cypress Creek Road, Suite 400, Fort Lauderdale, FL 33009 (1711). 

On February 19, 2019, the Debtors registered the fictitious names “1 GC Collections” and “1 West Collections” with the 

Florida Department of State. 

Case 19-01636-RAM Doc 42 Filed 03/30/21 Page 1 of 5
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dismissal in the form attached hereto as Exhibit A. 

DATED: March 30, 2021 DATED: March 30, 2021

Markowitz Ringel Trusty & Hartog, P.A. 

Attorneys for the Plaintiff 

9130 South Dadeland Blvd, Suite 1800 

Miami, Florida 33156 

Tel: (305) 670-5000 

Fax: (305) 670-5011 

Kaniuk Law Office, P.A. 

Attorneys for the Defendants 

1615 S. Congress Avenue, Suite 103 

Delray Beach, Florida 33445 

Tel: (561) 292-2127 

By: /s/ Alan R. Rosenberg 

Alan R. Rosenberg 

Fla. Bar No. 92004 

Email arosenberg@mrthlaw.com

By: /s/ Ronald Scott Kaniuk* 

Ronald Scott Kaniuk 

Fla. Bar No. 0112240 

 Email ron@kaniuklawoffice.com

 *electronically signed with permission 

 

Case 19-01636-RAM Doc 42 Filed 03/30/21 Page 2 of 5
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CERTIFICATE OF SERVICE 

I HEREBY CERTIFY that a true and correct copy of the foregoing was served on all counsel of 

record or pro se parties identified on the following Service List via the Court’s CM/ECF notification to 

those parties who are registered CM/ECF participants in this case on March 30, 2021. 

/s/ Alan R. Rosenberg 

Alan R. Rosenberg 

Service List 

Via Electronic Mail Notice To:

The following is the list of parties who are currently on the list to receive email 

notice/service for this case. 

 Ronald S Kaniuk ron@kaniuklawoffice.com 

 Alan R Rosenberg arosenberg@mrthlaw.com, 

gruiz@mrthlaw.com,jgarey@mrthlaw.com,ycandia@mrthlaw.com,mrthbkc@gmail.

com 

Case 19-01636-RAM Doc 42 Filed 03/30/21 Page 3 of 5
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EXHIBIT A 

UNITED STATES BANKRUPTCY COURT 

SOUTHERN DISTRICT OF FLORIDA 

MIAMI DIVISION 

www.flsb.uscourts.gov 

 

In re: CASE NO.: 18-19121-BKC-RAM 

1 GLOBAL CAPITAL LLC, et. al., CHAPTER 11 

 (Jointly Administered) 

Debtors. 

 / 

 

RAPID FINANCIAL SERVICES, LLC, 

 

 Plaintiff, ADV. CASE NO.: 19-01636-RAM 

v. 

 

HILLSBOROUGH RIVER PHARMACY, INC., 

and AMBROSE CHUKWUEKE, 

 

 Defendants. 

 / 

ORDER DISMISSING ADVERSARY PROCEEDING 

THIS MATTER came before the Court on the Parties’ Joint Stipulation of Dismissal of Adversary 

Case 19-01636-RAM Doc 42 Filed 03/30/21 Page 4 of 5
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Proceeding [ECF No. ____] (the “Stipulation”). The Court, having been informed of the Parties’ 

agreement to the dismissal of this adversary proceeding, ORDERS as follows: 

1. The adversary proceeding is dismissed, with each party to bear their own attorneys’ fees 

and costs. 

# # # 

Submitted by: 

Alan R. Rosenberg, Esq. 

Markowitz, Ringel, Trusty & Hartog, P.A. 

Counsel to the Plaintiff 

9130 South Dadeland Blvd., Suite 1800 

Miami, Florida 33156 

Tel: (305) 670-5000 

Copies to:

Alan R. Rosenberg, Esq. 

(Attorney Rosenberg is directed to mail a copy of this Order to all interested parties and to file a 

certificate of service).

Case 19-01636-RAM Doc 42 Filed 03/30/21 Page 5 of 5