10143702-2 

UNITED STATES BANKRUPTCY COURT 

SOUTHERN DISTRICT OF FLORIDA 

FORT LAUDERDALE DIVISION 

www.flsb.uscourts.gov 

In re: 

 

TAMARAC 10200, LLC and Case No. ____________________ 

UNIPHARMA, LLC, Case No. ____________________ 

 Debtors1. Chapter 11 Cases 

 (Joint Administration Pending) 

___________________________________/ 

DEBTORS’ EX PARTE MOTION FOR AUTHORIZATION TO FILE 

CONSOLIDATED CHAPTER 11 CASE MANAGEMENT SUMMARY 

Tamarac 10200, LLC (“Tamarac”) and Unipharma, LLC (“Unipharma”, and together 

with Tamarac, collectively, the “Debtors”), by and through their proposed undersigned counsel, 

file this Debtors’ Ex Parte Motion for Authorization to File Consolidated Chapter 11 Case 

Management Summary (the “Motion”). The Motion, filed on an ex parte basis, seeks 

authorization for the Debtors to file a consolidated Chapter 11 Case Management Summary. In 

support of this Motion, the Debtors rely upon the Declaration of Neil F. Luria in Support of 

Chapter 11 Petitions and First Day Pleadings (the “First Day Declaration”) which has been filed 

with the Court on the date hereof and incorporated herein by reference and respectfully represent 

as follows: 

Jurisdiction and Venue 

1. This Court has jurisdiction over this matter pursuant to 28 U.S.C. §§ 157 and 

1334. This is a core proceeding pursuant to 28 U.S.C. § 157(b).

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

1 The last four digits of each Debtor’s federal tax identification number are Tamarac 10200, LLC (2050) and 

Unipharma, LLC (8962). The address of the Debtors is 10200 N.W. 67th Street, Tamarac, FL 33321. 

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3. The statutory predicates for the relief sought herein are sections 105(a), 1107(a) 

and 1108 of chapter 11 of title 11 of the United States Code (the “Bankruptcy Code”). 

Procedural Background 

4. On the date hereof (the “Petition Date”), each of the Debtors filed a voluntary 

petition for relief under chapter 11 of the Bankruptcy Code. 

5. The Debtors are operating their businesses and managing their affairs as debtors 

in possession pursuant to sections 1107(a) and 1108 of the Bankruptcy Code. 

6. For a detailed description of the Debtors and their operations, the Debtors 

respectfully refer the Court and parties in interest to the First Day Declaration. 

Relief Requested 

7. In accordance with Local Rule 2081-1(B), the debtor in possession in a chapter 11 

case is directed to file with the Court, within the earlier of three business days after relief is 

entered, or one business day prior to the date of the first scheduled hearing, a Chapter 11 Case 

Management Summary (the “Case Management Summary”) providing certain information 

regarding the assets, liabilities and financial affairs of chapter 11 debtors. 

8. The Debtors have each filed in their respective chapter 11 cases, ex parte motions 

seeking joint administration of these chapter 11 cases. 

9. By this Motion, the Debtors respectfully request that the Court authorize them to 

file a consolidated Case Management Summary, reflecting the asset, liability and financial 

information of each of the Debtors. The Debtors request authority to file a consolidated Case 

Management Summary, as the filing of a separate Case Management Summary for each of the 

Debtors would be burdensome. In addition, much of the information contained in the Case 

Management Summary is either duplicative or solely applies to Unipharma, which is the 

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operating company, and the filing of a consolidated Case Management Summary is more 

efficient and will provide the Court and parties-in-interest with a more accurate financial picture 

of the Debtors. 

WHEREFORE, the Debtors respectfully request the entry of an Order in the form 

attached hereto as Exhibit “A” (i) granting the requested relief; (ii) authorizing the Debtors to 

file a consolidated Case Management Summary, with the reservation of the right of the U.S. 

Trustee to request that the Debtors each prepare and file a separate Case Management Summary 

should the U.S. Trustee deem it necessary; and (iii) granting such other and further relief as the 

Court deems just and proper. 

Dated: December 7, 2020 Respectfully submitted, 

 BERGER SINGERMAN LLP 

 Proposed Counsel for Debtors in Possession 

1450 Brickell Avenue, Suite 1900 

 Miami, FL 33131 

 Telephone: (305) 755-9500 

 Facsimile: (305) 714-4340 

 By: /s/ Christopher Andrew Jarvinen 

 Paul Steven Singerman 

 Florida Bar No. 0378860 

 singerman@bergersingerman.com 

 Christopher Andrew Jarvinen 

 Florida Bar No. 21745 

 cjarvinen@bergersingerman.com 

Case 20-23346-PDR Doc 16 Filed 12/07/20 Page 3 of 6
10143702-2 

EXHIBIT “A” 

(PROPOSED ORDER)

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10143720-2 

UNITED STATES BANKRUPTCY COURT 

SOUTHERN DISTRICT OF FLORIDA 

FORT LAUDERDALE DIVISION 

www.flsb.uscourts.gov 

In re: 

 

TAMARAC 10200, LLC and Case No. ____________________ 

UNIPHARMA, LLC, Case No. ____________________ 

 Debtors1

. Chapter 11 Cases 

 (Joint Administration Pending) 

___________________________________/ 

ORDER GRANTING DEBTORS’ EX PARTE MOTION FOR AUTHORIZATION TO 

FILE CONSOLIDATED CHAPTER 11 CASE MANAGEMENT SUMMARY 

THIS MATTER having come before the Court, without a hearing, upon the Debtors’ Ex 

Parte Motion for Authorization to File Consolidated Chapter 11 Case Management Summary

[ECF No. __] (the “Motion”) filed by the above-captioned debtors in possession (collectively, 

the “Debtors”). The Motion, filed on an ex parte basis, seeks entry of an order authorizing the 

Debtors to file a consolidated Case Management Summary. The Court finds that (i) it has 

jurisdiction over the matters raised in the Motion pursuant to 28 U.S.C. §§ 157 and 1334; (ii) this 

1 The last four digits of each Debtor’s federal tax identification number are Tamarac 10200, LLC (2050) and 

Unipharma, LLC (8962). The address of the Debtors is 10200 N.W. 67th Street, Tamarac, FL 33321. 

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is a core proceeding pursuant to 28 U.S.C. § 157(b)(2)(A), and that this Court may enter a final 

order consistent with Article III of the Constitution; (iii) venue is proper before this Court 

pursuant to 28 U.S.C. §§ 1408 and 1409; (iv) the relief requested in the Motion is in the best 

interests of the Debtors, their estates, their creditors and other parties in interest; (v) notice of the 

Motion was appropriate under the circumstances and no other notice need be provided; and (vi) 

upon review of the record before the Court, including the legal and factual bases set forth in the 

Motion and the First Day Declaration, good and sufficient cause exists to grant the relief 

requested. Accordingly, it is 

ORDERED that: 

1. The Motion is GRANTED. 

2. The Debtors are authorized to file a consolidated Case Management Summary, 

with the reservation of the right of the U.S. Trustee to request that the Debtors each prepare and 

file a separate Case Management Summary should the U.S. Trustee deem it necessary. 

3. The Court shall retain jurisdiction over any matter or dispute arising from or 

relating to the implementation of this Order. 

# # # 

Submitted by: 

Christopher Andrew Jarvinen, Esq. 

cjarvinen@bergersingerman.com

BERGER SINGERMAN LLP 

1450 Brickell Avenue, Ste. 1900 

Miami, FL 33131 

Telephone: (305) 755-9500 

Facsimile: (305) 714-4340 

(Christopher Andrew Jarvinen, Esq. is directed to serve a copy of this order on interested parties 

and file with the Court a certificate of service.) 

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