57496080;1 

UNITED STATES BANKRUPTCY COURT 

SOUTHERN DISTRICT OF FLORIDA 

WEST PALM BEACH DIVISION 

In re: 

HELLENIC PETROLEUM LLC, 

Alleged Debtor. 

____________________________________/ 

Case No.: 21-12317-EPK 

Chapter 7 (Involuntary) 

F.T. MARITIME SERVICES LTD’S RESPONSE TO THE ALLEGED DEBTOR’S 

MOTION TO EXTEND TIME TO FILE RESPONSE TO INVOLUNTARY PETITION 

F.T. Maritime Services LTD (“F.T. Maritime”), by and through undersigned counsel, files 

this Response to the Motion to Extend Time to File Response to Involuntary Petition (the “Motion 

for Extension”) (Doc. 30) filed by Alleged Debtor, Hellenic Petroleum, LLC (“Hellenic” or the 

“Alleged Debtor”), and in support thereof says: 

1. On March 10, 2021, Petitioning Creditor, Pro Petroleum, LLC (the “Petitioning 

Creditor”), filed a petition for involuntary bankruptcy against Hellenic. 

2. F.T. Maritime is a creditor of Hellenic and is owed over $7,000,000. While F.T. 

Maritime has not, at this time, joined the three petitioning creditors in filing a petition, F.T. 

Maritime will be severely prejudiced if the Motion for Extension is granted. 

3. Pursuant to Fed. R. Bankr. P. 1011(b), Alleged Debtor is required to respond to the 

involuntary petition by today, April 1, 2021. 

4. In the Motion for Extension, Hellenic requests an extension of fourteen (14) days 

to this deadline. 

5. As the Court and all parties are well aware, Hellenic currently may continue to 

operate normally and has the ability to dispose of property as if the involuntary case has not been 

Case 21-12317-EPK Doc 32 Filed 04/01/21 Page 1 of 6
2 

57496080;1 

filed pursuant to 11 U.S.C. § 303(f) until the Court rules whether or not the involuntary bankruptcy 

is appropriate. 

6. Hellenic's Motion for Extension fundamentally requests Court approval to have the 

ability to operate normally beyond the statutory deadline despite the fact that Hellenic itself has 

stated in court filings that it is not operating. Specifically, Hellenic has stated that it has no ability 

to purchase fuel and "without the ability to purchase fuel, Hellenic has no fuel to sell." See

Response (Doc. 19 at page 7, par. 18). 

7. The defenses to an involuntary petition are statutory in nature, limited, not overly 

complex and typically consist of issues relating to the existence of the appropriate amount of 

eligible creditors, whether or not those creditors' claims are contingent or disputed and whether or 

not a debtor is generally paying debts as they become due pursuant to 11 U.S.C. § 303. 

8. Hellenic should not require an additional two weeks to respond to the involuntary 

petition since it has already had notice for three weeks to prepare a response. 

9. In fact, Hellenic appears well aware of the facts at issue as it filed an extensive and 

detailed response to Petitioning Creditor's Emergency Motion for Appointment of an Interim 

Trustee Pursuant to 11 U.S.C. § 303(g) (Doc. 7), which involves similar issues to any response 

Hellenic would file to the involuntary petition. 

10. Hellenic's Motion for Extension, if granted, would severely prejudice both the 

petitioning creditors and other creditors, such as F.T. Maritime as it would allow Hellenic to 

continue to operate and potentially dispose of property that would otherwise benefit the bankruptcy 

estate. 

Case 21-12317-EPK Doc 32 Filed 04/01/21 Page 2 of 6
3 

57496080;1 

WHEREFORE, F.T. Maritime Services LTD respectfully requests this Court enter an Order 

denying the Motion for Extension or granting the Motion for Extension for a shorter time frame, 

and granting such other and further relief as the Court deems just and proper. 

Dated: April 1, 2021 Respectfully submitted, 

AKERMAN LLP 

By: /s/ Christian P. George 

Christian P. George 

Florida Bar No.: 41055 

Email: christian.george@akerman.com 

Katherine C. Fackler 

Florida Bar No.: 0068549 

Email: katherine.fackler@akerman.com 

50 North Laura Street, Suite 3100 

Jacksonville, FL 32202 

Telephone: (904) 798-3700 

Facsimile: (904) 798-3730 

and 

Catherine Douglas Kretzschmar 

Florida Bar No.: 85843 

Email: catherine.kretzschmar@akerman.com 

AKERMAN LLP 

201 E. Las Olas Boulevard, Suite 1800 

Fort Lauderdale, FL 33301 

Telephone: (954) 463-2700 

Facsimile: (954) 463-2224 

Attorneys for F.T. Maritime Services LTD 

Case 21-12317-EPK Doc 32 Filed 04/01/21 Page 3 of 6
4 

57496080;1 

ATTORNEY CERTIFICATION 

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). 

CERTIFICATE OF SERVICE 

I HEREBY CERTIFY that on April 1, 2021, 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 on those 

parties who are registered CM/ECF participants in this case as indicated on the attached Service 

List. 

By: /s/ Christian P. George

Christian P. George, Esq. 

Case 21-12317-EPK Doc 32 Filed 04/01/21 Page 4 of 6
5 

57496080;1 

SERVICE LIST 

21-12317-EPK Notice will be electronically mailed to: 

Michael R. Bakst, Esq. on behalf of Interested Party Mark Griffin 

efileu1094@gmlaw.com, ecf.alert+bakst@titlexi.com;efileu1092@gmlaw.com; 

efileu2170@gmlaw.com;efileu386@gmlaw.com

Michael R. Bakst, Esq. on behalf of Petitioning Creditor Pro Petroleum, LLC 

efileu1094@gmlaw.com, ecf.alert+bakst@titlexi.com;efileu1092@gmlaw.com; 

efileu2170@gmlaw.com;efileu386@gmlaw.com

Rilyn A. Carnahan, Esq. on behalf of Petitioning Creditor Pro Petroleum, LLC 

rilyn.carnahan@gmlaw.com, efileu1092@gmlaw.com;efileu1089@gmlaw.com; 

efileu2170@gmlaw.com;efileu1435@gmlaw.com;efileu1094@gmlaw.com;efileu1093@gmlaw.

com;gregory.stolzberg@gmlaw.com;efileu2299@gmlaw.com

Rilyn A. Carnahan, Esq. on behalf of Petitioning Creditor Renewable Energy Group, Inc. 

rilyn.carnahan@gmlaw.com, efileu1092@gmlaw.com;efileu1089@gmlaw.com; 

efileu2170@gmlaw.com;efileu1435@gmlaw.com;efileu1094@gmlaw.com;efileu1093@gmlaw.

com;gregory.stolzberg@gmlaw.com;efileu2299@gmlaw.com

Rilyn A. Carnahan, Esq. on behalf of Petitioning Creditor Xtreme Fuel Transport, Inc. 

rilyn.carnahan@gmlaw.com, efileu1092@gmlaw.com;efileu1089@gmlaw.com; 

efileu2170@gmlaw.com;efileu1435@gmlaw.com;efileu1094@gmlaw.com;efileu1093@gmlaw.

com;gregory.stolzberg@gmlaw.com;efileu2299@gmlaw.com

Robert P. Charbonneau, Esq. on behalf of Creditor DRO Barite LLC 

rpc@agentislaw.com, nsocorro@agentislaw.com;bankruptcy@agentislaw.com; 

bankruptcy.ecc@ecf.courtdrive.com

Robert P. Charbonneau, Esq. on behalf of Creditor Sallyport Commercial Finance, LLC 

rpc@agentislaw.com, nsocorro@agentislaw.com;bankruptcy@agentislaw.com; 

bankruptcy.ecc@ecf.courtdrive.com

Patrick R. Dorsey on behalf of Debtor Hellenic Petroleum LLC 

pdorsey@slp.law, dlocascio@slp.law;dwoodall@slp.law;pmouton@slp.law; 

pdorsey@ecf.courtdrive.com

Christian Peter George on behalf of Creditor F.T. Maritime Services LTD 

christian.george@akerman.com, susan.scott@akerman.com,jennifer.meehan@akerman.com

Gabriel M. Hartsell on behalf of Creditor VFS US LLC 

gabriel.hartsell@quarles.com, sybil.aytch@quarles.com

Case 21-12317-EPK Doc 32 Filed 04/01/21 Page 5 of 6
6 

57496080;1 

Office of the US Trustee 

USTPRegion21.MM.ECF@usdoj.gov

Bradley S. Shraiberg on behalf of Debtor Hellenic Petroleum LLC 

bss@slp.law, dwoodall@slp.law;dwoodall@ecf.courtdrive.com; 

dlocascio@slp.law;pmouton@slp.law

Case 21-12317-EPK Doc 32 Filed 04/01/21 Page 6 of 6