55798679;1 - 1 - 

AKERMAN LLP, LAS OLAS CENTRE II, SUITE 1600, 350 EAST LAS OLAS BOULEVARD, FORT LAUDERDALE, FL 33301-2999 

UNITED STATES BANKRUPTCY COURT 

SOUTHERN DISTRICT OF FLORIDA 

WEST PALM BEACH DIVISION 

www.flsb.uscourts.gov 

IN RE: 

HALS REALTY ASSOCIATES LIMITED Case No.: 20-13103-MAM 

PARTNERSHIP, 

Chapter 11 

Debtor. 

_________________________________/ 

NOTICE OF FILING BUDGET 

Undersigned counsel hereby gives notice of the filing of attached Cash Collateral Budget 

and the comparison of actual against projections for the prior cash collateral budget with respect 

to Trustee's request for further use of cash collateral in this bankruptcy case pursuant to the Order 

Granting Debtor’s Emergency Motion to Use Cash Collateral of Bank of America N.A., on an 

Interim Basis entered on September 28, 2020 (ECF No. 130). 

Dated: December 21, 2020 Respectfully submitted, 

 /s/ Eyal Berger 

Eyal Berger, Esq. 

Florida Bar Number: 011069 

eyal.berger@akerman.com

AKERMAN LLP 

Las Olas Centre II, Suite 1600 

350 East Las Olas Boulevard 

Fort Lauderdale, FL 33301-2999 

Phone: (954) 463-2700 

Fax: (954) 463-2224 

Counsel for Michael I. Goldberg, Ch 11 Trustee 

Case 20-13103-MAM Doc 151 Filed 12/21/20 Page 1 of 7
55798679;1 - 2 - 

AKERMAN LLP, LAS OLAS CENTRE II, SUITE 1600, 350 EAST LAS OLAS BOULEVARD, FORT LAUDERDALE, FL 33301-2999 

CERTIFICATE OF SERVICE 

I HEREBY CERTIFY that on December 21, 2020, I electronically filed the foregoing 

document with the Clerk of the Court using CM/ECF. I also certify that the foregoing document 

is being served this day by transmission of Notices of Electronic Filing generated by CM/ECF to 

those parties registered to receive electronic notices of filing in this case or via U.S. mail as listed 

in the below service list. 

By: /s/ Eyal Berger 

 Eyal Berger, Esq. 

SERVICE LIST 

20-13103-MAM Notice will be electronically mailed to: 

Paul A Avron, Esq. on behalf of Creditor S.M.S. Co. 

pavron@bergersingerman.com, 

efile@bergersingerman.com;efile@ecf.inforuptcy.com;mmorgan@bergersingerman.com 

Eyal Berger, Esq. on behalf of Accountant Soneet Kapila 

eyal.berger@akerman.com, jeanette.martinez@akerman.com 

Eyal Berger, Esq. on behalf of Trustee Michael Goldberg 

eyal.berger@akerman.com, jeanette.martinez@akerman.com 

Heidi A Feinman on behalf of U.S. Trustee Office of the US Trustee 

Heidi.A.Feinman@usdoj.gov 

Jeffrey D Fisher, Esq on behalf of Creditor Love Family II LLC 

eservice@fphlegal.com 

Jeffrey D Fisher, Esq on behalf of Creditor Love Family LLC 

eservice@fphlegal.com 

Robert C Furr, Esq on behalf of Debtor Hals Realty Associates Limited Partnership 

ltitus@furrcohen.com, 

atty_furrcohen@bluestylus.com;cworkinger@furrcohen.com;staff1@furrcohen.com 

Michael I Goldberg, Esq on behalf of Trustee Michael Goldberg 

michael.goldberg@akerman.com, charlene.cerda@akerman.com 

Laudy Luna, Esq. on behalf of Creditor BANK OF AMERICA, N.A. 

ll@lgplaw.com, de@lgplaw.com 

Case 20-13103-MAM Doc 151 Filed 12/21/20 Page 2 of 7
55798679;1 - 3 - 

AKERMAN LLP, LAS OLAS CENTRE II, SUITE 1600, 350 EAST LAS OLAS BOULEVARD, FORT LAUDERDALE, FL 33301-2999 

Orfelia M Mayor on behalf of Creditor Palm Beach County Tax Collector 

ombankruptcy@mayorbankruptcy.com, legalservices@pbctax.com;rgroff@cinlegal.com 

Office of the US Trustee 

USTPRegion21.MM.ECF@usdoj.gov 

Paul Steven Singerman, Esq on behalf of Creditor S.M.S. Co. 

singerman@bergersingerman.com, 

mdiaz@bergersingerman.com;efile@bergersingerman.com;efile@ecf.inforuptcy.com 

20-13103-MAM Notice will not be electronically mailed to: 

Alan Barbee 

1400 Centrepark Blvd #860 

West Palm Beach, FL 33401 

Larry Bernstein 

1580 Ocean Avenue 

Brooklyn, NY 11230 

Howard DuBosar 

3010 N. Military Trail, Suite 210 

Boca Raton, FL 33431 

Case 20-13103-MAM Doc 151 Filed 12/21/20 Page 3 of 7
Notes 1/31/2021

Revenue

Rent 2 $ 131,428

Total Revenue 131,428

Operating Expenses

Mortgage 32,100 

Sales Tax 3 7,500

Insurance 4 75,000

Other / Contingency 5,000 

Total Operating Expenses 119,600

Chapter 11 Bankruptcy Expenses

Professional Fees 5 250,000

U.S Trustee Fees 6 4,875

Total Chapter 11 Bankruptcy Expenses 254,875

Net cash flow (deficit) (243,047) $ 

Beginning cash balance available for operations 7 1,842,513

Net cash flow (deficit) (243,047) 

Ending cash balance available for operations 1,599,466 $ 

Restricted cash 8 1,030,288

Available cash from operations 1,599,466 

Total ending cash balance 2,629,754 $ 

SEE ACCOMPANYING NOTES

Source: Discussions and historical data provided by management.

1 Month Budget: January 1, 2021 through January 31, 2021 

HALS REALTY ASSOCIATES LIMITED PARTNERSHIP

CASE NO. 20-13103-BKC-MAM

UNITED STATES BANKRUPTCY COURT

SOUTHERN DISTRICT OF FLORIDA

WEST PALM BEACH DIVISION

Page 1 of 2.......

Case 20-13103-MAM Doc 151 Filed 12/21/20 Page 4 of 7
No. Description

1

The Trustee from time to time makes written or oral forward-looking statements concerning expectations, beliefs, 

plans, objectives, future events or performance and underlying assumptions and other statements that are not 

historical facts. These statements are "forward-looking statements." Generally, the inclusion of the words "believe", 

"could", "should", "estimate", "expect", "intend", "anticipate", "will", "plan", "target", "forecast" and similar expressions 

identify statements that constitute "forward-looking statements." All statements addressing developments that the 

Trustee expects or anticipates will occur in the future, including statements relating to values, future financial condition, 

assets, real property and timing of their disposition, as well as statements expressing optimism or pessimism about 

future results, are forward-looking statements.

The forward-looking statements are based upon the Trustee's then-current views and assumptions regarding future 

developments and are applicable only as of the dates of such statements. By their nature, all forward-looking 

statements involve risks and uncertainties. The Trustee assumes no obligation to update or review any forwardlooking information to reflect actual results, changes in assumptions or changes in other factors affecting forwardlooking information, whether as a result of new information, future events or otherwise. There can be no assurance 

that the Trustee has correctly identified and appropriately assessed all factors affecting the Company and its assets. 

For these reasons, you are cautioned not to place undue reliance on any forward-looking statements.

2 The gross rental income was derived from historical collections from March 5, 2020 through June 30, 2020 and 

includes sales tax. Rental income is generated from three tenants based on their current leases.

3 Sales tax is due on the 20th of each month for the previous month.

4 Policy D42248976002 held with Westchester Fire Insurance Company is to expire on February 1, 2021 and the 

renewal payment is estimated to be $75,000.

5 Administrative expenses for the Trustee and his professionals are estimated at $50,000 per month. Professional fees 

are expected to be paid when fee apps are filed in subsequent months.

6 The fees due to the US Trustee is payable quarterly and based on the monthly operating reports filed with the 

Bankruptcy Court. The payment will be due in January 2021.

7 The bank balance is comprised of the available cash as of December 21, 2020 in Iberia bank account ending 6243, 

Bank of America account ending 0434, and City National Bank account ending 1273.

8

The Debtor maintains two certificates of deposits at two financial institutions and the funds are not available without 

incurring fees and penalties. The accrued interest has not been calculated. The two certificates of deposits are as 

follows:

1) First Citizen Bank account ending 6965 - Value: $61,735 - Maturity Date: 09/19/2020

2) Iberia Bank account ending 6865 - Value: $966,884 - Maturity Date: 05/01/2022

The Trustee issued a letter to First Citizen Bank, directing them to turnover the funds for the certificate of deposit that 

matured in September.

Source: Discussions and historical data provided by management.

HALS REALTY ASSOCIATES LIMITED PARTNERSHIP

CASE NO. 20-13103-BKC-MAM

UNITED STATES BANKRUPTCY COURT

SOUTHERN DISTRICT OF FLORIDA

WEST PALM BEACH DIVISION

Notes - 1 Month Budget: January 1, 2021 through January 31, 2021

Page 2 of 2.......

Case 20-13103-MAM Doc 151 Filed 12/21/20 Page 5 of 7
Notes Budget Actual Variance ($) Budget v Actual Variance (%) Budget v Actual Budget Actual Variance ($) Budget v Actual Variance (%) Budget v Actual Budget Actual Variance ($) Budget v Actual Variance (%) Budget v Actual 

Revenue

Rent 3 $ 131,428 $ - 131,428 $ 0% $ 131,428 $ - 131,428 $ 0% $ 34,734 131,428 $ (96, $ 694) -74% $ 

Total Revenue 131,428 - 131,428 0% 131,428 - 131,428 0% 34,734 131,428 (96,694) -74% 

Operating Expenses

Mortgage 32,100 32,100 - 0% 32,100 32,100 - 0% 32,100 32,100 - 0% 

 

Sales Tax 4 7,408 7,500 92 1% 7,405 7,500 95 1% 7,405 7,500 95 1% 

Real Estate Tax - - - 0% 375,000 10,536 364,464 3% - - - 0% 

Insurance 5 - 75,000 75,000 100% - - - 0% - - - 0% 

Other / Contingency 5,000 96 4,904 98% 70 5,000 4,930 99% 30 5,000 4,970 99% 

Total Operating Expenses 39,604 119,600 79,996 67% 419,600 15,562 404,038 4% 39,535 44,600 5,065 11% 

Chapter 11 Bankruptcy Expenses

Professional Fees 6 - - - 0% - 150,000 150,000 100% - - - 0% 

U.S Trustee Fees 7 975 1,625 650 40% - - - 0% - - - 0% 

Total Chapter 11 Bankruptcy Expenses 975 1,625 650 40% - 150,000 150,000 100% - - - 0% 

Net cash flow (deficit) 10,203 $ 90,849 $ 80,646 $ 790% $ ( (438,172) $ 272,611) $ 165,562 38% $ (4, 86,828 $ (91, 801) $ 629) -106% $ 

Beginning cash balance available for operations 8 1, 1,401,405 96,545 497,951 1, 2, 411,608 119,925 708,316 1, 973,436 847,314 

873,878 

Matured CDs 9 - 531,125 - 531,125 - - - - - 

Net cash flow (deficit) 10,203 90,849 80,646 ( ( 438,172) 272,611) 86,828 165,562 (4, (91, 801) 

629) 

Ending cash balance available for operations $ 2, 1,411,608 $ 119,925 $ 708,316 $ 1, 973,436 $ 847,314 $ 1, 873,878 $ 1, 060,264 $ 842,513 $ 

782,249 $ 

Restricted cash 9 1, 1,559,582 1, 030,288 1, 030,288 1, 559,582 1, 030,288 1, 030,288 1, 559,582 1, 030,288 

030,288 

Available cash from operations 1,411,608 2, 2, 119,925 119,925 1, 973,436 1, 847,314 1, 847,314 1, 060,264 1, 842,513 

842,513 

Total ending cash balance 2,971,190 $ 3, $ 3, 150,212 $ 2, 150,212 $ 2, 533,018 $ 2, 877,602 $ 2, 877,602 $ 2, 619,846 $ 2, 872,801 $ 

872,801 $ 

SEE ACCOMPANYING NOTES

Source: Discussions and historical data provided by management.

Actual v. Budget: October 1, 2020 through December 21, 2020 (Note 1)

HALS REALTY ASSOCIATES LIMITED PARTNERSHIP

CASE NO. 20-13103-BKC-MAM

UNITED STATES BANKRUPTCY COURT

SOUTHERN DISTRICT OF FLORIDA

WEST PALM BEACH DIVISION

Oct-20 Nov-20 Dec-20 (Note 2) 

Case 20-13103-MAM Doc 151 Filed 12/21/20 Page 6 of 7
No. Description

1

The Trustee from time to time makes written or oral forward-looking statements concerning expectations, beliefs, 

plans, objectives, future events or performance and underlying assumptions and other statements that are not 

historical facts. These statements are "forward-looking statements." Generally, the inclusion of the words "believe", 

"could", "should", "estimate", "expect", "intend", "anticipate", "will", "plan", "target", "forecast" and similar expressions 

identify statements that constitute "forward-looking statements." All statements addressing developments that the 

Trustee expects or anticipates will occur in the future, including statements relating to values, future financial condition, 

assets, real property and timing of their disposition, as well as statements expressing optimism or pessimism about 

future results, are forward-looking statements.

The forward-looking statements are based upon the Trustee's then-current views and assumptions regarding future 

developments and are applicable only as of the dates of such statements. By their nature, all forward-looking 

statements involve risks and uncertainties. The Trustee assumes no obligation to update or review any forwardlooking information to reflect actual results, changes in assumptions or changes in other factors affecting forwardlooking information, whether as a result of new information, future events or otherwise. There can be no assurance 

that the Trustee has correctly identified and appropriately assessed all factors affecting the Company and its assets. 

For these reasons, you are cautioned not to place undue reliance on any forward-looking statements.

2 As of December 21, 2020, rent has only been collected from one tenant. The remaining rent is expected to be 

collected later in the month.

3 The gross rental income was derived from historical collections from March 5, 2020 through June 30, 2020 and 

includes sales tax. Rental income is generated from three tenants based on their current leases.

4 Sales tax is due on the 20th of each month for the previous month.

5 Policy D42248976002 held with Westchester Fire Insurance Company was extended through February 1, 2021 and the 

estimated payment of $75,000 is expected to be made in January 2021.

6 Administrative expenses for the Trustee and his professionals are estimated at $50,000 per month. Professional fees 

are expected to be paid when fee apps are filed in subsequent months.

7 The fees due to the US Trustee is payable quarterly and based on the monthly operating reports filed with the 

Bankruptcy Court. The first payment will be due in October 2020.

8

The budgeted bank balance is comprised of the available cash as of September 16, 2020 in Iberia bank account 

ending 6243, Bank of America account ending 0434, and City National Bank account ending 1273. The actual bank 

balance is comprised of the available cash as of September 30, 2020, which accounted for additional bank activity 

subsequent to September 16th and resulted in a net surplus of $96,545.

9

The certificates of deposits for account ending 3039 and 8400 at Iberia Bank matured and were turned over to the 

Trustee in October 2020. The Debtor maintains two additional certificates of deposits at two financial institutions and 

the funds are not available without incurring fees and penalties. The accrued interest has not been calculated. The 

two certificates of deposits are as follows:

1) First Citizen Bank account ending 6965 - Value: $61,760 - Expected Maturity Date: 09/19/2020

2) Iberia Bank account ending 6865 - Value: $967,706 - Expected Maturity Date: 05/01/2022

The Trustee issued a letter to First Citizen Bank, directing them to turnover the funds for the certificate of deposit that 

matured in September.

Source: Discussions and historical data provided by management.

HALS REALTY ASSOCIATES LIMITED PARTNERSHIP

CASE NO. 20-13103-BKC-MAM

UNITED STATES BANKRUPTCY COURT

SOUTHERN DISTRICT OF FLORIDA

WEST PALM BEACH DIVISION

Actual v. Budget: October 1, 2020 through December 21, 2020

Page 2 of 2.......

Case 20-13103-MAM Doc 151 Filed 12/21/20 Page 7 of 7