54699157;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 July 28, 2020 (ECF No. 106). 

Dated: September 18, 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 121 Filed 09/18/20 Page 1 of 7
54699157;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 September 18, 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 121 Filed 09/18/20 Page 2 of 7
54699157;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 121 Filed 09/18/20 Page 3 of 7
Notes 10/31/2020 11/30/2020 12/31/2020 Total

Revenue

Rent 2 $ 131,428 131,428 $ 131,428 $ 394,284 $ 

Total Revenue 131,428 131,428 131,428 394,284 

Operating Expenses

Mortgage 32,100 32,100 32,100 96,300 

Sales Tax 3 7,500 7,500 7,500 22,500 

Real Estate Tax 4 375,000 - - 375,000 

Insurance 75,000 - - 75,000 

Other / Contingency 5,000 5,000 5,000 15,000 

Total Operating Expenses 419,600 119,600 44,600 583,800 

Chapter 11 Bankruptcy Expenses

Professional Fees 5 150,000 - - 150,000 

U.S Trustee Fees 6 - 1,625 - 1,625 

Total Chapter 11 Bankruptcy Expenses 150,000 1,625 - 151,625 

Net cash flow (deficit) 10,203 $ (438,172) $ 86,828 $ (341,141) $ 

Beginning cash balance available for 

operations 7 1,411,608 1,401,405 973,436 1,401,405 

Net cash flow (deficit) 10,203 (438,172) 86,828 (341,141) 

Ending cash balance available for 

operations $ 973,436 1,411,608 $ 1,060,264 $ 1,060,264 $ 

Restricted cash 8 1,559,582 1,559,582 1,559,582 1,559,582 

Available cash from operations 1,411,608 973,436 1,060,264 1,060,264 

Total ending cash balance 2,971,190 $ 2,533,018 $ 2,619,846 $ 2,619,846 $ 

SEE ACCOMPANYING NOTES

Source: Discussions and historical data provided by management.

3 Month Budget: October 1, 2020 through December 31, 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

Page 1 of 2.......

Case 20-13103-MAM Doc 121 Filed 09/18/20 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 Real estate taxes were estimated based on the taxes paid in 2019.

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 first payment will be due in October 2020.

7 The 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.

8

The Debtor maintains four 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 four 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 3039 - Value: $518,546 - Maturity Date: 10/12/2020

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

4) Iberia Bank account ending 8400 - Value: $11,570 - Maturity Date: 10/02/2020

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 - 3 Month Budget: October 1, 2020 through December 31, 2020

Page 2 of 2.......

Case 20-13103-MAM Doc 121 Filed 09/18/20 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 

Revenue

Rent 3 $ 131,428 114,000 $ 17,428 $ 15% $ 34,734 114,000 $ (79,266) $ -70% $ 

228,000 

Total Revenue 131,428 114,000 17,428 15% 34,734 114,000 (79,266) -70% 

228,000 

Operating Expenses

Mortgage 32,100 27,334 4,766 15% 32,100 32,100 - 0% 64,200 

Sales Tax 4 6,182 7,500 1,318 18% 7,405 7,500 95 1% 

15,000 

Other / Contingency 5 320 5,000 4,680 94% 22,327 5,000 (17,327) -347% 

10,000 

Total Operating Expenses 33,836 44,600 10,764 24% 61,832 44,600 (17,232) -39% 

89,200 

Chapter 11 Bankruptcy Expenses

Professional Fees 6 - 50,000 50,000 100% - 50,000 50,000 100% 

100,000 

U.S Trustee Fees 7 - - - 0% - - - 0% 

- 

Total Chapter 11 Bankruptcy Expenses - 50,000 50,000 100% - 50,000 50,000 100% 

100,000 

Net cash flow (deficit) 19,400 $ 97,592 $ 78,192 $ 403% $ (27,098) 19,400 $ (46,498) $ -240% $ 

38,800 

Beginning cash balance available for operations 8 1,330,911 985,735 345,176 1,005,135 1,428,503 423,368 985,735 

Net cash flow (deficit) 19,400 97,592 78,192 19,400 (27,098) (46,498) 38,800 

Ending cash balance available for operations $ 1,428,503 1,005,135 $ 423,368 $ 1,024,535 $ 1,401,405 $ 376,870 $ 1,024,535 $ 

Restricted cash 9 1,559,582 1,558,735 1,559,582 1,558,735 1,559,582 1,559,582 1,558,735 

Available cash from operations 1,005,135 1,428,503 1,428,503 1,024,535 1,401,405 1,401,405 1,024,535 

Total ending cash balance 2,563,870 $ 2,988,085 $ 2,988,085 $ 2,583,270 $ 2,960,987 $ 2,960,987 $ 2,583,270 $ 

SEE ACCOMPANYING NOTES

Source: Discussions and historical data provided by management.

Actual v. Budget: August 1, 2020 through September 16, 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

Aug-20 Sep-20 (Note 2) 

Case 20-13103-MAM Doc 121 Filed 09/18/20 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 September 16, 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 The unfavorable variance for Other / Contingency expenses was due to a previously undisclosed insurance expense 

for coverage set to expire in October 2020.

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 July 10, 2020 in Iberia bank account ending 6243 

and Bank of America account ending 0434. The actual bank balance is comprised of the available cash as of July 31, 

2020 in Iberia bank account ending 6243, Bank of America account ending 0434, and City National Bank account 

ending 1273.

9

The Debtor maintains four 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 four certificates of deposits are as 

follows:

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

2) Iberia Bank account ending 3039 - Value: $518,546 - Maturity Date: 10/12/2020

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

4) Iberia Bank account ending 8400 - Value: $11,570 - Maturity Date: 10/02/2020

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: August 1, 2020 through September 16, 2020

Page 2 of 2.......

Case 20-13103-MAM Doc 121 Filed 09/18/20 Page 7 of 7