UNITED STATES BANKRUPTCY COURT 

SOUTHERN DISTRICT OF FLORIDA 

MIAMI DIVISION 

www.flsb.uscourts.gov 

In re: Case No. 19-22483-AJC 

COSTA HOLLYWOOD PROPERTY Chapter 11 

OWNER, LLC, 

Debtor. 

______________________________________/ 

OBJECTION TO CLAIMS 

(CLAIM NO. 47 OF GUSTAVO CARLOS LESCOVICH RAMOS, 

CLAIM NO. 49 (AS AMENDED) OF RUBEN EDUARDO REYES HERRERA 

AND ASTRID AURORA AREVALO MOLINA, CLAIM NO. 57 OF RENACER 

LLC, AND CLAIM NO. 124 OF ESTATE OF PABLO HAEFFNER) 

IMPORTANT NOTICE TO CREDITOR: 

THIS IS AN OBJECTION TO YOUR CLAIM 

This objection seeks either to disallow and/or reduce the amount and/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. 

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 3007-11, Maria M. Yip, Trustee of the 

Costa Hollywood Property Owner, LLC Liquidating Trust (the “Liquidating Trustee”) objects to the 

following claims filed in this case: 

1 Notwithstanding the requirements of Bankruptcy Rule 3007, up to five objections to claim may be included in one 

pleading. See Local Rule 3007-1(C). 

Case 19-22483-AJC Doc 791 Filed 04/19/22 Page 1 of 5
Claim 

No. 

Name and 

Address of 

Claimant 

Amount of 

Claim 

Basis for Objection and 

Recommended Disposition 

47 Gustavo 

Carlos 

Lescovich 

Ramos, c/o 

The Levey 

Law Firm, 

P.A. 

1688 

Meridian 

Avenue, 

Suite 900 

Miami 

Beach, FL 

33139 

$260,000.00 The claim is for a deposit under a purchase and sale 

agreement. The claimant provided no supporting 

documentation supporting the amount claimed. The 

debtor’s schedules (ECF No. 235) dispute the debt to the 

claimant. The debtor’s records and information provided 

by Jairo Romero reflect that the claimant defaulted under 

its purchase and sale agreement with the debtor by failing 

to close on Unit S-508 by April 18, 2018, as required by 

the agreement and the 10-day notice to close dated March 

22, 2018. Section 3.10 of the confirmed plan (ECF No. 

287) provides that a purchaser shall have no claim against 

the debtor in the event that the purchaser breached or 

defaulted under their purchase and sale agreement. The 

Liquidating Trustee object to this claim and requests that 

it be disallowed in its entirety and stricken from the record. 

The Liquidating Trustee reserves the right to amend this 

objection and/or assert further objections to the claim at a 

later date upon discovery of further information and 

documentation, and in an abundance of caution moves to 

extend the deadline to further object to this claim.

49 (as 

amen

ded) 

Ruben 

Eduardo 

Reyes 

Herrera and 

Astrid 

Aurora 

Arevalo 

Molina 

c/o Julie 

Feigeles, 

Esq. 

7900 Peters 

Rd, Ste B200 

Fort 

Lauderdale, 

FL 33324 

$312,000.00 The claim is for a deposit under a purchase and sale 

agreement. The claimant provided no supporting 

documentation pursuant to Bankruptcy Rule 3001 

supporting the amount claimed. The debtor’s schedules 

(ECF No. 235) dispute the debt to the claimant. The 

debtor’s records and information provided by Jairo 

Romero reflect that the claimant defaulted under its 

purchase and sale agreement with the debtor by failing to 

close on Unit S-408 by April 13, 2018, as required by the 

agreement and the 10-day notice to close dated March 22, 

2018. Section 3.10 of the confirmed plan (ECF No. 287) 

provides that a purchaser shall have no claim against the 

debtor in the event that the purchaser breached or defaulted 

under their purchase and sale agreement. The Liquidating 

Trustee objects to this claim and requests that it be 

disallowed in its entirety and stricken from the record. 

In the event that the court adjudicates that the claimant is 

entitled to a return of its deposit, Section 3.10 of the 

confirmed plan provides that the claimant shall receive any 

portion of its deposit held in escrow and that the balance 

shall be treated as an allowed general unsecured claim. The 

Case 19-22483-AJC Doc 791 Filed 04/19/22 Page 2 of 5
Claim 

No. 

Name and 

Address of 

Claimant 

Amount of 

Claim 

Basis for Objection and 

Recommended Disposition 

Liquidating Trustee is not aware of any deposits currently 

held in escrow. Accordingly, in the event that the court 

allows any portion of the claim, the secured portion of the 

claim should be recharacterized as an unsecured claim. 

The Liquidating Trustee reserves the right to amend this 

objection and/or assert further objections to the claim at a 

later date upon discovery of further information and 

documentation and in an abundance of caution moves to 

extend the deadline to further object to this claim.

57 Renacer 

LLC 

c/o Zen 

Automotore

s S.A. 

Av. Del 

Libertador 

12909, 

Martinez 

(1640) 

Buenos 

Aires - 

Argentina 

$401,250.00 The claim is for a deposit under a purchase and sale 

agreement. The claimant did not provide supporting 

documentation pursuant to Bankruptcy Rule 3001. The 

debtor’s schedules (ECF No. 235) dispute the debt to the 

claimant. The debtor’s records and information provided 

by Jairo Romero reflect that the claimant defaulted under 

its purchase agreement with the debtor by failing to close 

on Unit N-531 by December 8, 2017, as required by the 

agreement and the 10-day notice to close dated November 

13, 2017. Section 3.10 of the confirmed plan (ECF No. 

287) provides that a purchaser shall have no claim against 

the debtor in the event that the purchaser breached or 

defaulted under their purchase and sale agreement. The 

Liquidating Trustee objects to this claim and requests that 

it be disallowed in its entirety and stricken from the record. 

In the event that the court adjudicates that the claimant is 

entitled to a return of its deposit, Section 3.10 of the 

confirmed plan provides that the claimant shall receive any 

portion of its deposit held in escrow and that the balance 

shall be treated as an allowed general unsecured claim. The 

Liquidating Trustee is not aware of any deposits currently 

held in escrow. Accordingly, in the event that the court 

allows any portion of the claim, the secured portion of the 

claim should be recharacterized as an unsecured claim. 

The Liquidating Trustee reserves the right to amend this 

objection and/or assert further objections to the claim at a 

later date upon discovery of further information and 

documentation, and in an abundance of caution moves to 

extend the deadline to further object to this claim.

124 Estate of 

Pablo 

$210,000.00 The claimant tardily filed the proof of claim after the 

deadline set for filing claims. The claim is for a deposit 

Case 19-22483-AJC Doc 791 Filed 04/19/22 Page 3 of 5
Claim 

No. 

Name and 

Address of 

Claimant 

Amount of 

Claim 

Basis for Objection and 

Recommended Disposition 

Haeffner 

c/o Robert 

C. Arnold, 

Esq. 

80 SW 8th 

Street, #200

Miami, FL 

33130 

under a purchase and sale agreement. The claimant did 

not provide supporting documentation pursuant to 

Bankruptcy Rule 3001. The debtor’s schedules (ECF No. 

235) dispute the debt to the claimant. The debtor’s records 

and information provided by Jairo Romero reflect that the 

claimant defaulted under its purchase and sale agreement 

with the debtor by failing to close on Unit S-219 by April 

4, 2018, as required by the agreement and the 10-day 

notice to close dated March 22, 2018. Section 3.10 of the 

confirmed plan (ECF No. 287) provides that a purchaser 

shall have no claim against the debtor in the event that the 

purchaser breached or defaulted under their purchase and 

sale agreement. This claim should be disallowed and 

stricken from the record. 

Section 3.10 of the confirmed plan (ECF No. 287) 

provides that a purchaser shall have no claim against the 

debtor in the event that the purchaser breached or 

defaulted under their purchase and sale agreement. In the 

event, however, that the court adjudicates that the 

claimant is entitled to a return of its deposit, Section 3.10 

of the confirmed plan provides that the claimant shall 

receive any portion of its deposit held in escrow and that 

the balance shall be treated as an allowed general 

unsecured claim. The Liquidating Trustee is not aware of 

any deposits currently held in escrow. Accordingly, in the 

event that the court allows any portion of the claim, the 

secured portion of the claim should be recharacterized as 

an unsecured claim. 

The Liquidating Trustee reserves the right to amend this 

objection and/or assert further objections to the claim at a 

later date upon discovery of further information and 

documentation, and in an abundance of caution moves to 

extend the deadline to further object to this claim.

Case 19-22483-AJC Doc 791 Filed 04/19/22 Page 4 of 5
DATED: April 19, 2022. LESSNE LAW

Counsel for Liquidating Trustee 

One Financial Plaza 

100 SE 3rd Avenue, 10th Floor 

Fort Lauderdale, FL 33394 

Phone: 954-372-5759 

By: /s/ Michael D. Lessne

Michael D. Lessne 

Florida Bar No.: 73881 

michael@lessne.law 

CERTIFICATE OF SERVICE 

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

19th day of April, 2022, by electronic transmission of Notices of Electronic Filing on all counsel 

of record or pro se parties identified on the CM/ECF service list maintained by the court in this 

case (including via email to Julie Feigeles at jf@womenatlawft.com and way@womenatlawfl.com

and Robert C. Arnold at bob@thevictorialawgroup.com and 

bankruptcy@thevictorialawgroup.com) and via first class U.S. Mail upon: Gustavo Carlos 

Lescovich Ramos, c/o The Levey Law Firm, P.A., 1688 Meridian Avenue, Suite 900, Miami 

Beach, FL 33139; Gustavo Carlos Lescovich Ramos, Parada 6 de la Brava, Edif Icon Bravia 

Depto #707, Punta de Este, URUGUAY; Ruben Eduardo Reyes Herrera and Astrid Aurora 

Arevalo Molina, c/o Julie Feigeles, Esq., 7900 Peters Rd, Ste B-200, Fort Lauderdale, FL 

33324; Renacer LLC, c/o Zen Automotores S.A., Av. Del Libertador 12909, Martinez (1640), 

Buenos Aires – Argentina; Estate of Pablo Haeffner, c/o Robert C. Arnold, Esq., 80 SW 8th 

Street, #200, Miami, FL 33130

/s/ Michael D. Lessne 

Michael D. Lessne 

Case 19-22483-AJC Doc 791 Filed 04/19/22 Page 5 of 5