UNITED STATES BANKRUPTCY COURT

SOUTHERN DISTRICT OF FLORIDA

MIAMI DIVISION

www.flsb.uscourts.gov

In re:

Chapter 11

IT’SUGAR FL I LLC, Case No. 20-20259-RAM

IT’SUGAR LLC, Case No. 20-20261-RAM

IT’SUGAR ATLANTIC CITY LLC, Case No. 20-20263-RAM

IT’SUGAR FLGC LLC, Case No. 20-20264-RAM

(Joint Administration)

Debtors.

_______________________________/

AMENDED1 APPLICATION OF THE DEBTORS FOR AN ORDER, ON AN INTERIM 

BASIS, AUTHORIZING THE EMPLOYMENT AND RETENTION OF 

RICKI S. FRIEDMAN, ESQ. AND THE LAW FIRM OF RICKI S. FRIEDMAN 

PLLC AS SPECIAL COUNSEL NUNC PRO TUNC TO SEPTEMBER 22, 2020

(Emergency Hearing Requested)

Basis for Requested Emergency Hearing

The Debtors respectfully request that the Court conduct a 

hearing on this Motion consistent with Local Rule 9013-1(F). 

Delay in obtaining approval of counsel’ s retention until a final 

hearing is scheduled will cause immediate and irreparable harm 

to the Debtors inasmuch as the Debtors are corporate entities 

which need legal counsel in order to negotiate leases relative to 

a first day motion. The Debtors respectfully request that the 

Court waive the provisions of Local Rule 9075-1 (B), which 

requires an affirmative statement that a bona fide effort was 

made in order to resolve the issues raised in this Motion, as the 

relief requested herein is urgent in nature and does not lend 

itself to advance resolution.

It’Sugar FL I LLC, It’Sugar LLC, It’Sugar Atlantic City LLC, and It’Sugar FLGC LLC

(collectively, “It’Sugar” or “Debtors”), by and through undersigned counsel, respectfully requests 

an Order of the Court, pursuant to § 327(e) of Title 11 of the United States Code, Rules 2014(a) 

and 2016 of the Federal Rules of Bankruptcy Procedure and Rules 2014-1 and 2016-1 of the Local 

1 Amended solely to seek hearing on an emergency basis.

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Rules for the United States Bankruptcy Court for the Southern District of Florida, authorizing the 

employment and retention of Ricki S. Friedman, Esquire (“Special Counsel”) and the Law Firm 

of Ricki S. Friedman PLLC (the “Firm”) nunc pro tunc to September 22, 2020 to represent the 

Debtors in this case as its special counsel, and states: 

JURISDICTION AND VENUE 

1. The United States Bankruptcy Court for the Southern District of Florida (the 

“Court”) has jurisdiction over the Debtors, property of the Debtors’ estates and this matter 

pursuant to 28 U.S.C. § 1334. This matter is a core proceeding within the meaning of 28 U.S.C. § 

157(b)(2). 

2. This Application is authorized by 11 U.S.C. §§ 327(e) and 330 and Rules 2014 and 

2016 of the Federal Rules of Bankruptcy Procedure (the “Bankruptcy Rules”), and Local Rules 

2014-1 and 2016-1. 

3. Venue in this Court is proper pursuant to 28 U.S.C. §§ 1408 and 1409. 

BACKGROUND 

4. The Debtors operate as a single business and are known throughout the industry as 

It'Sugar. It'Sugar is a specialty candy retailer whose products include bulk candy, candy in giant 

packaging, and licensed and novelty items. It'Sugar’s portfolio includes approximately 100 retail 

locations across 28 states. 

5. On September 22, 2020 (the “Petition Date”), each of the Debtors filed voluntary 

petitions under Chapter 11 of the United States Bankruptcy Code. Each Debtor continues to 

operate its business and manage its properties as debtors-in-possession pursuant to 11 U.S.C. §§ 

1107(a) and 1108. 

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Case 20-20259-RAM Doc 25 Filed 09/23/20 Page 3 of 19
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RELIEF REQUESTED 

6. The Debtors desire to employ and retain Special Counsel and the Firm nunc pro 

tunc to September 22, 2020 as its special counsel in connection with commercial real estate and 

general contracts. The Firm formerly represented IT’SUGAR LLC, IT’SUGAR FL 1 LLC AND 

IT’SUGAR ATLANTIC CITY LLC in connection with (a) negotiating leases and amendments, 

(b) negotiating estoppels and SNDA’s, (c) interpreting lease provisions and (d) negotiate general 

contracts. 

7. The Debtors desire to retain Special Counsel and the Firm to represent them in the 

negotiation of commercial real estate agreements and related documents as set forth in the 

Engagement Letter attached hereto as “Exhibit A” because: (a) Special Counsel has extensive 

experience and knowledge in the field of commercial real estate, (b) Special Counsel is very 

familiar with the Debtors’ businesses especially as it relates to the scope of her proposed 

employment, and (c) the Debtors believe Special Counsel is both able and uniquely qualified to 

represent them in these Chapter 11 Cases for the limited purposes described below. 

8. The professional services Special Counsel and the Firm may be required to render, 

in a special counsel role, include but are not limited to (“Professional Services”): 

a) Negotiate leases and amendments; 

b) Interpretation of lease provisions; 

c) Resolving disputes with landlords; 

d) Negotiation of SNDA’s and estoppels; and 

e) Negotiation of contracts. 

Case 20-20259-RAM Doc 25 Filed 09/23/20 Page 4 of 19
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9. The Debtors believe that Special Counsel and the Firm are duly qualified to perform 

the requested Professional Services. 

10. The Firm’s proposed compensation shall continue at the Firm’s previously agreed 

upon hourly rates with the Debtors at $350.00 for partners, plus reimbursement of actual, necessary 

expenses and other charges incurred by the Firm. 

11. No agreement exists, nor will any be made, to share any compensation received by 

the Firm for its services with any other person or firm, except as permitted by 11 U.S.C. § 504(b) 

and Bankruptcy Rule 2016. 

12. No promises have been made to or received by the Firm as to payment or 

compensation in connection with these bankruptcy cases other than in accordance with the 

provisions of the United States Bankruptcy Code an applicable Bankruptcy Rules. 

13. To the best of the Debtor’s knowledge, and as set forth in the proposed attorney's 

declaration (“Friedman Declaration”) attached to this motion as Exhibit B Special Counsel and 

the Firm do not have an adverse interest with respect to the matter on which Special Counsel and 

the Firm are to be employed as required by 11 U.S.C. § 327(e). 

14. The Firm intends to apply to the Court for allowances of compensation and 

reimbursement of out-of-pocket expenses incurred on or after the Petition Date in connection with 

this Chapter 11 case on an hourly basis, subject to Court approval and in accordance with the 

applicable provisions of the Bankruptcy Code, the Bankruptcy Rules, the Local Rules, the 

guidelines established by the United States Trustee for the Southern District of Florida and any 

further orders of this Court. 

Case 20-20259-RAM Doc 25 Filed 09/23/20 Page 5 of 19
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NUNC PRO TUNC RELIEF IS APPROPRIATE 

15. Pursuant to the Debtors’ request, Special Counsel and the Firm have agreed to serve 

as special counsel on and after the Petition Date with assurances that the Debtors would seek 

approval of its employment and retention nunc pro tunc to the Petition Date so that the Firm may 

be compensated for its pre-Application services. The Debtors believe that no party in interest will 

be prejudiced by the granting of the nunc pro tunc employment, as provided in this Application, 

because Special Counsel and the Firm have provided, and continue to provide, valuable services 

to the Debtors’ estates in the interim period. 

16. The Debtors further request authority for Meland Budwick, P.A. to maintain time 

records in support of any application for compensation and reimbursement of costs with respect to 

the Debtors on a consolidated basis without the necessity for tracking time separately as to each 

Debtor inasmuch as It’Sugar LLC pays for each of the Debtors’ expenses. 

 

[REMAINDER OF PAGE INTENTIONALLY LEFT BLANK] 

 

Case 20-20259-RAM Doc 25 Filed 09/23/20 Page 6 of 19
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 WHEREFORE, the Debtor respectfully requests entry of an order in the form attached 

hereto as Exhibit C (i) authorizing the employment and retention of Special Counsel and the Firm 

nunc pro tunc to the Petition Date, as special counsel to the Debtors in these chapter 11 cases on a 

general retainer, pursuant to 11 U.S.C. §§ 327(e) and 330; and (ii) granting such other and further 

relief as the Court deems just and proper. 

Dated: September 23, 2020. 

 s/ Michael S. Budwick 

Michael S. Budwick, Esquire 

Florida Bar No. 938777 

mbudwick@melandbudwick.com

Joshua W. Dobin, Esquire 

Florida Bar No. 93696 

jdobin@melandbudwick.com 

James C. Moon, Esquire 

Florida Bar No. 938211 

jmoon@melandbudwick.com 

MELAND BUDWICK, P.A. 

3200 Southeast Financial Center 

200 South Biscayne Boulevard 

Miami, Florida 33131 

Telephone: (305) 358-6363 

Telecopy: (305) 358-1221 

Proposed Attorneys for Debtors 

Case 20-20259-RAM Doc 25 Filed 09/23/20 Page 7 of 19
The Law Firm of Ricki S. Friedman PLLC

1 Huckleberry Lane

Hewlett Harbor, New York 1 1557

(516) 428-3978

Anton Gladnikov

Chief Financial Officer

IT'SUGAR LLC

Dear Anton:

I am pleased that IT'SUGAR LLC and its related entities: (i) IT'SUGAR FLGC LLC, (ii)

IT'SUGAR FL 1 LLC and (iii) IT'SUGAR ATLANTIC CITY LLC (collectively, the "IT'SUGAR

LLC ENTITIES") are interested in engaging this firm to act as special counsel for the IT'SUGAR

ENTITIES in connection with the following professional services ("Professional Services"): (i)

Negotiate leases and amendments, (ii) Interpretation of lease provisions, (iii) Resolving disputes

with landlord's, (iv) Negotiation of SNDA's and estoppels and (v )Negotiation of contracts.

I understand my retention requires and is subject to the filing of an employment application

with the Bankruptcy Court (the "Application") and entry of an order by the Bankruptcy Court

approving my employment ("Retention Order"). To the extent the Application or Retention Order

contradicts any term of this Legal Representation Agreement, the Application or Retention Order, as the case may be, shall control. I have agreed that my engagement is limited to my performance

of the Professional Services.

My fee for this representation will be Three Hundred Fifty ($350.00) Dollars per hour.

Any expenses which are incurred by this representation will also be billed to you, provided that all

expenses will be preapproved by IT'SUGAR LLC ENTITIES. No agreement exists, nor will be

made, to share any compensation received by my firm for its services with any other person or firm,

except as permitted by 1 1 U.S.C. § 504(b) and Bankruptcy Rule 2016. The firm intends to apply

to the Bankruptcy Court for the Southern District of Florida ("Bankruptcy Court") for

allowances of compensation and reimbursement of out-of-pocket expenses incurred on or

after the date the IT'SUGAR ENTITES file chapter 1 1 bankruptcy petitions (the "Petition

Date") on an hourly basis, subject to Court approval and in accordance with the applicable

provisions of the Bankruptcy Code, the Bankruptcy Rules, the Local Rules for the

Bankruptcy Court, the guidelines established by the United States Trustee for the Southern

District of Florida and any further orders of the Bankruptcy Court. . Subject to general standards of professional responsibility of the legal profession, I will

have the right to terminate my representation of you if any fees and/or expenses are not timely paid

after a statement with respect to them is rendered. IT'SUGAR LLC ENTITIES may terminate this

engagement at any time upon written notice to me. If the engagement is terminated, IT'SUGAR

LLC ENTITIES shall be liable for all fees and expenses incurred to the date of such exercise subject

to approval by the Bankruptcy Court.

Please review this document carefully and advise me if any of the information is incorrect, or if any

additional details should be included.

{ 02488397.DOCX. }

EXHIBIT A

Case 20-20259-RAM Doc 25 Filed 09/23/20 Page 8 of 19
I appreciate your interest in allowing me to represent the IT'SUGAR LLC ENTITIES in your

commercial real estate negotiations.

Sincerely,

Ricki S. Friedman Esq.

Agreed to and accepted on September 21, 2020:

IT'SUGAR LLC

By:

IT'SUGAR FLGC LLC

By:

IT'SUGAR ATLANTIC CITY LLC

By:

IT'SUGAR FL 1 LLC

By:

{ 02488397.DOCX. }

Case 20-20259-RAM Doc 25 Filed 09/23/20 Page 9 of 19
I appreciate your interest in allowing me to represent the IT'SUGAR LLC ENTITIES in

commercial real estate negotiations.

your

Sincerely,

Kicki S. Friedman tsq.

<r\

Agreed to and accepted on September 21, 2020:

IT'SUGAR LLC

By:

IT'SUGAR FLGC LLC

By:

IT'SUGAR ATLANTIC CITY LLC

IT'SUGAR FL 1 LLC

By:

{ 02488397.DOCX. i

I

Case 20-20259-RAM Doc 25 Filed 09/23/20 Page 10 of 19
{02487200.DOCX.}

UNITED STATES BANKRUPTCY COURT 

SOUTHERN DISTRICT OF FLORIDA 

MIAMI DIVISION 

www.flsb.uscourts.gov

In re: 

 Chapter 11 

IT’SUGAR FL I LLC, Case No. 20-20259-RAM 

IT’SUGAR LLC, Case No. 20-20261-RAM 

IT’SUGAR ATLANTIC CITY LLC, Case No. 20-20263-RAM 

IT’SUGAR FLGC LLC, Case No. 20-20264-RAM 

 (Joint Administration pending) 

Debtors. 

_______________________________/

DECLARATION OF RICKI S. FRIEDMAN, ESQ. ON BEHALF OF THE LAW FIRM 

OF RICKI S. FRIEDMAN PLLC AS PROPOSED SPECIAL COUNSEL TO DEBTOR

 

 Ricki S. Friedman of the Law Firm of Ricki S. Friedman PLLC (the “Firm”) submits this 

Declaration pursuant to 28 U.S.C. §1746, sections 327(e) of the United States Bankruptcy Code 

(“Bankruptcy Code”) and Fed R. Bankr. P. 2014(a) and 2016(b) (“Bankruptcy Rules”), in support 

of the Application of the Debtors for an Order Authorizing the Employment and Retention of Ricki 

S. Friedman, Esq. and the Law Firm of Ricki S. Friedman PLLC as Special Counsel Nunc Pro 

Tunc to September 22, 2019 (the “Application”). 

1. I am a shareholder of the Firm, which maintains offices at 1 Huckleberry Lane, 

Hewlett Harbor, New York 11557. 

2. Neither I nor the Firm represents any interest adverse to the captioned Debtors or 

their estates with respect to the matters for which I am to be employed. I am admitted to practice 

in the state courts of New York . 

3. I am authorized to make this Declaration on behalf of the Firm and I am the attorney 

at the Firm that will be responsible for the representation of the Debtors in these cases, in 

accordance with the scope of services defined in the Application. 

EXHIBIT B

Case 20-20259-RAM Doc 25 Filed 09/23/20 Page 11 of 19
{02487200.DOCX.} 2

4. This Declaration is submitted pursuant to Bankruptcy Rule 2014(a) in support of 

the Application. 

5. The Firm has extensive experience and knowledge in the field of commercial estate. 

The Firm is familiar with the Debtors’ businesses and financial affairs, and is well qualified to 

represent the Debtors in these chapter 11 cases in an efficient and timely manner. 

6. The Firm formerly represented IT’SUGAR LLC, IT’SUGAR FL 1 LLC AND 

IT’SUGAR ATLANTIC CITY LLC in connection with (a) negotiating leases and amendments, 

(b) negotiating estoppels and SNDA’s, (c) interpreting lease provisions and (d) negotiate general 

contracts. 

7. I have extensive experience and knowledge in the field of commercial real estate, 

(b) I am very familiar with the Debtors’ businesses especially as it relates to the scope of my 

proposed employment, and (c) I am both able and uniquely qualified to represent the Debtors in 

these Chapter 11 Cases for the limited purposes of performing the Professional Services (defined 

below). 

8. The professional services Special Counsel and the Firm may be required to render, 

in a special counsel role, include but are not limited to (“Professional Services”): 

a) Negotiate leases and amendments; 

b) Interpretation of lease provisions; 

c) Resolving disputes with landlords; 

d) Negotiation of SNDA’s and estoppels; and 

e) Negotiation of contracts. 

Case 20-20259-RAM Doc 25 Filed 09/23/20 Page 12 of 19
{02487200.DOCX.} 3

9. The Firm’s proposed compensation shall continue at the Firm’s previously agreed 

upon hourly rates with the Debtors at $350.00 for partners, plus reimbursement of actual, necessary 

expenses and other charges incurred by the Firm. 

10. No agreement exists, nor will any be made, to share any compensation received by 

the Firm for its services with any other person or firm, except as permitted by 11 U.S.C. § 504(b) 

and Bankruptcy Rule 2016. 

11. No promises have been made to or received by the Firm as to payment or 

compensation in connection with these bankruptcy cases other than in accordance with the 

provisions of the United States Bankruptcy Code an applicable Bankruptcy Rules. 

12. Prepetition, the Firm is not owed any money by the Debtors. Further, the Firm 

received $22,112.75 from Debtors in the 90 days prior to bankruptcy filing. 

13. Except for the performance of services for the Debtors, I do not and will not 

represent any other entity in connection with this case, and I will not accept any fee from any other 

party or parties in this case in connection with my work in the instant case. 

14. The Firm does not have an adverse interest with respect to the matters on which I 

and the Firm are to be employed as required by 11 U.S.C. § 327(e). 

15. Pursuant to the disclosure requirement of Bankruptcy Rule 5002(a) of the 

Bankruptcy Rules, to the best of my knowledge, neither I nor any person with whom I am 

associated in the practice of law at the Firm is a relative by blood or marriage to any Bankruptcy 

Judge of the United States Bankruptcy Court for the Southern District of Florida. 

16. Based on the foregoing, the Firm believes none of its representations or 

engagements described above are materially adverse to the interests of the estates or any class of 

creditors or equity security holders. In addition, pursuant to section 327(e) of the Bankruptcy Code, 

Case 20-20259-RAM Doc 25 Filed 09/23/20 Page 13 of 19
{02487200.DOCX.} 4

the Firm should not be disqualified from acting as the Debtors’ special counsel simply because it 

has represented in the past, and may continue to represent creditors or parties in interest in matters 

that are wholly unrelated to the Debtors and these bankruptcy cases. Accordingly, the Firm submits 

that it does not represent an interest adverse to the bankruptcy estates of the Debtors and does not 

represent a creditor in connection with these bankruptcy cases.

17. The Firm intends to apply to the Court for allowances of compensation and 

reimbursement of out-of-pocket expenses incurred on or after September 22, 2020 in connection 

with this Chapter 11 case on an hourly basis, subject to Court approval and in accordance with the 

applicable provisions of the Bankruptcy Code, the Bankruptcy Rules and any further orders of this 

Court. 

18. I am authorized to submit this Declaration on behalf of the Firm, and if called upon 

to testify, I would testify competently as to the facts set forth herein. 

[Remainder of page intentionally left blank. Next page is signature page.] 

 

Case 20-20259-RAM Doc 25 Filed 09/23/20 Page 14 of 19
Pursuant to 28 U.S.C. § 1746, 1 declare under penalty of perjury that the foregoing is true

and correct.

This Declaration is executed by me on this day of September, 2020.

Qj. CfoijS

Ricki S. Friedman

Law Firm of Ricki S. Friedman PLLC

1 Huckleberry Lane,

Hewlett Harbor, New York 1 1557

ricki@rickifriedman.com

Tel: (5 16) 428-3978

5

{ 02487200.DOCX.}

Case 20-20259-RAM Doc 25 Filed 09/23/20 Page 15 of 19
1

EXHIBIT C 

UNITED STATES BANKRUPTCY COURT 

SOUTHERN DISTRICT OF FLORIDA 

MIAMI DIVISION 

www.flsb.uscourts.gov

In re: 

 Chapter 11 

IT’SUGAR FL I LLC, Case No. 20-20259-RAM 

IT’SUGAR LLC, Case No. 20-20261-RAM 

IT’SUGAR ATLANTIC CITY LLC, Case No. 20-20263-RAM 

IT’SUGAR FLGC LLC, Case No. 20-20264-RAM 

 (Joint Administration pending) 

Debtors. 

_______________________________/ 

INTERIM ORDER AUTHORIZING THE EMPLOYMENT AND 

RETENTION OF RICKI S. FRIEDMAN, ESQ. AS SPECIAL COUNSEL 

FOR THE CHAPTER 11 DEBTORS-IN-POSSESSION ON AN INTERIM BASIS 

NUNC PRO TUNC TO THE PETITION DATE AND SETTING FINAL HEARING 

 THIS MATTER came before the Court on ____, 2020 at ___ ___.m. upon the 

Application of the Debtors for an Order, on an Interim Basis, Authorizing the Employment and 

Retention of Ricki S. Friedman, Esquire as Special Counsel for the Debtors and Debtors in 

Possession Nunc Pro Tunc to the Petition Date [ECF No. ___] (the “Application”), pursuant to 

Case 20-20259-RAM Doc 25 Filed 09/23/20 Page 16 of 19
2

§ 327(e) of Title 11 of the United States Code (the “Bankruptcy Code”), Rules 2014(a), 2016 

and 6003 of the Federal Rules of Bankruptcy Procedure (the “Bankruptcy Rules”) and Rules 

2014-1 and 2016-1 of the Local Rules for the United States Bankruptcy Court for the Southern 

District of Florida (the “Local Rules”); the Court having reviewed the Application, the 

declaration of Ricki S. Friedman, Esq. in support of the Application, (the “Friedman 

Declaration”); the Court being satisfied based upon the representations made in the Application 

and the Friedman Declaration that (a) Ricki S. Friedman, Esquire (“Special Counsel”) and the 

Law Firm of Ricki S. Friedman PLLC (the “Firm”) does not represent or hold any interest 

adverse to the debtor or to the estate with respect to the matter on which such attorney is to be 

employed and Local Rule 2014-1; due and proper notice of the Application having been 

provided, and after due deliberation and sufficient cause appearing therefore, it is accordingly

ORDERED AND ADJUDGED as follows: 

1. The Application is GRANTED on an interim basis, nunc pro tunc to the Petition 

Date. 

2. It’Sugar FL I LLC, It’Sugar LLC (“ITS or Sugar”), It’Sugar Atlantic City LLC, 

and It’Sugar FLGC LLC (collectively, the “Debtors”) are authorized to employ and retain the 

Firm as their special counsel in these Chapter 11 cases in accordance with the terms and 

conditions set forth in the Application and this Interim Order.

3. The Firm shall apply for compensation for professional services rendered and 

reimbursement of expenses incurred in connection with the Debtors’ Chapter 11 cases in 

compliance with the applicable provisions of the Bankruptcy Code, the Bankruptcy Rules, the 

Local Rules, guidelines established by the Office of the United States Trustee for the Southern 

District of Florida and any other applicable procedures and orders of the Court. 

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3

4. The Court shall conduct a final hearing (the “Final Hearing”) on the Application 

on _____________, at ___________, prevailing Eastern Time, by telephone through 

CourtSolutions. To participate through CourtSolutions, you must make a reservation in advance 

no later than 3:00 p.m., one business day before the date of the hearing. Reservations should be 

arranged online at https://www.court-solutions.com/. If a party is unable to register online, a 

reservation may also be made by telephone at (917) 746−7476. 

5. Any party in interest objecting to the relief sought in the Application shall serve 

and file written objections, which objections shall be served upon (a) the Debtors; (b) Debtor’s 

Counsel; (c) the Office of the United States Trustee for the Southern District of Florida; (d) the 

entities listed on the Master Service List, if any, filed pursuant to Local Bankruptcy Rule 2002-

1(K); and (e) counsel to any Official Committee of Unsecured Creditors Committee, to the 

extent one is appointed prior to the Final Hearing (collectively, the “Notice Parties”) and shall be 

filed with the Clerk of the United States Bankruptcy Court, Southern District of Florida, to allow 

actual receipt by the foregoing no later than ___________________ at 4:30 p.m., prevailing 

Eastern Time. 

6. Notice will be provided to all parties by mailing a copy of this Interim Order 

setting the Final Hearing upon all parties on the Master Service List pursuant to Local Rule 

2002-1 (H), Designation of Master Service List in Chapter 11 Cases. 

7. In the event the Application is not granted on a final basis, the Firm shall be 

authorized to submit a fee application with this Court for compensation for services rendered in 

the period between the Petition Date and the Final Hearing. Any party in interest may object to 

the fee application; provided, however, that such party shall file such objection with this Court 

and serve a copy of the objection upon the Notice Parties. 

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4

8. Time records in support of any application for compensation and reimbursement 

of costs may be maintained by the Firm with respect to the Debtors on a consolidated basis 

without the necessity for tracking time separately as to each Debtor. 

9. The requirements for emergency motions set forth in Local Rule 9075-1 and for 

entry of the relief requested earlier than the period set forth in Bankruptcy Rule 6003 are 

satisfied by the contents of the Application. 

10. The Debtors are authorized to take all actions necessary to effectuate the relief 

granted pursuant to this Interim Order in accordance with the Application and the record. 

11. Entry of this Interim Order is without prejudice to the rights of any party-ininterest to interpose an objection to the Application, and any such objection will be considered 

on a de novo basis at the Final Hearing. 

12. This Court shall retain jurisdiction to hear and determine all matters arising from 

or related to the implementation of this Interim Order. 

### 

Submitted By: 

Joshua W. Dobin, Esquire 

Florida Bar No. 93696 

jdobin@melandbudwick.com

MELAND BUDWICK, P.A. 

Counsel for Debtors 

3200 Southeast Financial Center 

200 South Biscayne Boulevard 

Miami, Florida 33131 

Telephone: (305) 358-6363 

Telefax: (305) 358-1221 

Copies Furnished To: 

Joshua W. Dobin, Esquire, is directed to serve copies of this Order on all parties in interest and 

to file a Certificate of Service. 

Case 20-20259-RAM Doc 25 Filed 09/23/20 Page 19 of 19