UNITED STATES BANKRUPTCY COURT 

SOUTHERN DISTRICT OF FLORIDA 

Miami Division 

www.flsb.uscourts.gov

In re: Chapter 11 

TRIPTYCH MIAMI HOLDINGS, LLC, Case No. 21-12375-BKC-RAM

 

Debtor. 

____________________________________/ 

 

EX-PARTE MOTION BY CHAPTER 11 

DEBTOR TO TRANSFER BANKRUPTCY CASE 

TRIPTYCH MIAMI HOLDINGS, LLC (the “Debtor”), by and through counsel, and 

pursuant to Fed. R. Bankr. P. 1015(b) and Local Rule 1015-1(B), hereby files this Ex-Parte Motion 

By Chapter 11 Debtor to Transfer Bankruptcy Case (the “Motion”) for entry of an order 

authorizing the transfer of the Debtor’s Chapter 11 Case to the Honorable Judge A. Jay Cristol. In 

support of this Motion, the Debtor respectfully represents as follows: 

Jurisdiction and Background 

1. The Court has jurisdiction over this Motion pursuant to 28 U.S.C. §§ 157 and 1334. 

This matter is a core proceeding pursuant to 28 U.S.C. § 157(b)(2). Venue of this proceeding is 

proper in this district and before this Court pursuant to 28 U.S.C. §§ 1408 and 1409. 

2. On March 12, 2021 (the “Petition Date”), the Debtor filed a voluntary petition for 

relief under Chapter 11 of the United States Bankruptcy Code, 11 U.S.C. §§101 et seq (the 

“Code”). 

3. Also on the Petition Date, AVENTURA HOTEL PROPERTIES, LLC (Case No. 

21-12374-BKC-AJC)(the “AHP Debtor”), an affiliate of the Debtor, filed a voluntary petition for 

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relief under Chapter 11 of the United States Bankruptcy Code, 11 U.S.C. §§101 et seq,. The AHP 

Debtor’s case was assigned to the Honorable A. Jay Cristol. 

4. The Debtor owns 100% of the membership interests in AVENTURA HOTEL 

PROPERTIES, LLC. As such, the Debtors are “affiliates” as that term is defined in Section 101(2) 

of the Bankruptcy Code and as used in Bankruptcy Rule 1015(b). 

5. Given the affiliation of the above Debtors and, more significantly, the common 

interests of the Debtors with respect to the reorganization of the Debtors’ estates, TRIPTYCH 

MIAMI HOLDINGS, LLC requests that this case assigned to Judge Robert A. Mark be transferred 

to Judge A. Jay Cristol so that the same can be jointly administered. 

6. The transfer of this Chapter 11 case is warranted because: (i) the Debtors are 

“affiliates” within the meaning of section 101(2) of the Code; (ii) administration of the cases will 

be organized and expedited; and (iii) judicial resources will be preserved. 

7. For these reasons, the Debtor respectfully request that the Bankruptcy Court enter 

an order transferring this case to Judge A. Jay Cristol as the first filed case was assigned to Judge 

A. Jay Cristol. 

10. A proposed Order granting this Motion has been uploaded to the Court via 

CM/ECF. 

WHEREFORE, the Chapter 11 Debtor, TRIPTYCH MIAMI HOLDINGS, LLC, 

respectfully requests the entry of an Order (i) transferring this case to Judge A. Jay Cristol; and (ii) 

granting such other and further relief as the Court deems appropriate. 

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Dated: March 14, 2021 

 Respectfully Submitted, 

 GENOVESE JOBLOVE & BATTISTA, P.A. 

 Proposed Attorneys for Debtors-in-Possession 

100 Southeast Second Street, Suite 4400 

 Miami, Florida 33131 

 Telephone: (305) 349-2300 

 By: /s/ Mariaelena Gayo-Guitian 

 Jesus M. Suarez, Esq. 

Florida Bar No. 60086 

jusarez@gjb-law.com 

Mariaelena Gayo-Guitian, Esq. 

Florida Bar No. 813818 

mguitian@gjb-law.com

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