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. 

______________________________/

DEBTOR, MERIDIAN MARINA & YACHT CLUB OF PALM CITY, LLC’S OBJECTION 

TO CLAIM OF CHARLES GOODMAN (CLAIM NUMBER 7)

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 claims filed in this case and on the grounds set forth therein. Accordingly, the 

claims should be stricken and disallowed.

Case 19-18585-MAM Doc 99 Filed 04/17/20 Page 1 of 3
Name of Claimant

Claim 

Amount

Claim 

Number

Basis for Objection and 

Recommended Disposition

Charles Goodman $18,461.23 Claim No. 7

Objection - The alleged damage to the 

creditor's boat totals $600.00. Claim 

shall be paid $600.00. Remaining 

amount of claim shall be stricken.

WHEREFORE, the Debtor respectfully requests 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 17th day of April 2020.

KELLEY, FULTON & KAPLAN, P.L.

Attorneys for the Debtor in Possession

1665 Palm Beach Lakes Blvd., Ste 1000

West Palm Beach, FL 33401

Phone (561) 491-1200

Facsimile (561) 684-3773

By: /s/ Craig I. Kelley, Esq.

CRAIG I. KELLEY, ESQUIRE

Florida Bar 782203 

Case 19-18585-MAM Doc 99 Filed 04/17/20 Page 2 of 3
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. 

• John P Carrigan jpc@reblawpa.com, mmj@reblawpa.com

• Heidi A Feinman Heidi.A.Feinman@usdoj.gov

• Dana L Kaplan dana@kelleylawoffice.com, 

tina@kelleylawoffice.com;craig@kelleylawoffice.com;cassandra@kelleylawoffice.

com;debbie@kelleylawoffice.com

• Craig I Kelley craig@kelleylawoffice.com, 

dana@kelleylawoffice.com,tina@kelleylawoffice.com,cassandra@kelleylawoffice

.com;debbie@kelleylawoffice.com

• Susan D. Lasky ECF@suelasky.com, 

ecfsuelasky@gmail.com;r48532@notify.bestcase.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). 

Meridian Marina & Yacht Club of Palm City, LLC

1400 SW Chapman Way

Palm City, FL 34990

Charles Goodman

3022 SW Lake Terrace

Palm City, FL 34990

Case 19-18585-MAM Doc 99 Filed 04/17/20 Page 3 of 3