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UNITED STATES BANKRUPTCY COURT 

SOUTHERN DISTRICT OF FLORIDA 

FT. LAUDERDALE DIVISION 

www.flsb.uscourts.gov

In re: 

LIBERTY POWER HOLDINGS, LLC, Case No.: 21-13797-SMG 

 Chapter 11 

 Debtor. 

____________________________________/ 

MOTION TO APPEAR PRO HAC VICE

I, Daniel N. Gonzalez (“Movant”), a member in good standing of the bar of the United 

States District Court for the Southern District of Florida and qualified to practice in this court, 

request that this court admit pro hac vice Abigail O’Brient, Esq., (“Visiting Attorney”), attorney 

admitted to practice and currently in good standing in the United States District Court for the 

Central, Eastern, Northern and Southern Districts of California and qualified to practice in this 

court, who proposes to act as counsel for Liberty Power Corp., LLC (“LPC” or the “Client”) in 

the case listed above-listed case. 

1. I am aware that the local rules of this court require a member in good standing of 

the bar of the United States District Court for the Southern District of Florida and qualified to 

practice in this court to act as local counsel for such Client, unless the court specifically authorizes 

an attorney not so admitted to act as local counsel. I understand that local counsel is required to 

participate in the preparation and presentation of, and accept service of all papers in, the case 

identified above in which the Visiting Attorney appear on behalf of such Client. 

2. I am a member in good standing of the bar of the United States District Court for 

the Southern District of Florida and qualified to practice in this court, and agree to act as local 

Case 21-13797-SMG Doc 26 Filed 04/22/21 Page 1 of 9
   

   

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counsel for the above-referenced Client in this case and in any adversary proceedings in this case 

in which the Visiting Attorney appear on behalf of the Client. I understand that I am required to 

participate in the preparation and the presentation of the case above and to accept service of all 

papers served in such case and proceedings. 

3. The order granting this Motion will serve to admit the Visiting Attorney to practice 

in the case noted above on behalf of the Client in which the Visiting Attorney appear on behalf of 

such Client. I understand that if I decline to serve as local counsel in any such adversary 

proceeding, separate local counsel must file an additional Motion to Appear Pro Hac Vice, and 

that absent such separate motion and an order of this court approving the same I will continue to 

act as local counsel for the Client in all such proceedings. 

4. The declaration of the Visiting Attorney required under Local Rule 2090-1(C)(2) 

is attached hereto as Exhibit A. 

5. A proposed order is attached hereto as Exhibit B. 

WHEREFORE, upon the foregoing representations, Movant respectfully requests an order 

of this Court authorizing the Visiting Attorney to appear pro hac vice in this case on behalf of the 

Client and indicating Movant as local counsel for the Client, and for such other and further relief 

as may be just. 

[Remainder of Page Intentionally Left Blank. Next Page Is Signature Page.] 

 

 

Case 21-13797-SMG Doc 26 Filed 04/22/21 Page 2 of 9
   

   

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CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a true and correct copy of the foregoing was served on 

April 22, 2021 via the Court's Notice of Electronic Filing upon the Registered Users listed on 

the attached Exhibit 1. 

 

/s/Daniel N. Gonzalez 

Daniel N. Gonzalez, Esq. 

Florida Bar No. 938777 

dgonzalez@melandbudwick.com 

MELAND BUDWICK, P.A. 

3200 Southeast Financial Center 

200 South Biscayne Boulevard 

Miami, Florida 33131 

Telephone: (305) 358-6363 

Telecopy: (305) 358-1221 

 Counsel for Liberty Power Corp., LLC

Case 21-13797-SMG Doc 26 Filed 04/22/21 Page 3 of 9
{02605097.DOC.} 

UNITED STATES BANKRUPTCY COURT 

SOUTHERN DISTRICT OF FLORIDA 

FT. LAUDERDALE DIVISION 

www.flsb.uscourts.gov

In re: 

LIBERTY POWER HOLDINGS, LLC, Case No.: 21-13797-SMG

Debtor. 

____________________________________/ 

AFFIDAVIT OF PROPOSED VISITING ATTORNEY 

I, ABIGAIL O’BRIENT, am a member in good standing of the bar of the State of 

California. I am a member in good standing of the bars of the United States District Court for 

Central, Eastern, Northern and Southern Districts of California, but am not admitted to the bar of 

the United States District Court for the Southern District of Florida. 

I certify that I have never been disbarred, that I am not currently suspended from the 

practice of law in the State of Florida or any other state, and that I am not currently suspended 

from the practice of law before any United States Court of Appeals, United States District Court, 

or United States Bankruptcy Court. 

I hereby request authority to appear pro hac vice in this case and in any adversary 

proceedings in this case on behalf of Liberty Power Corp., LLC (the “Client”). I designate Daniel 

N. Gonzalez, Esq., of Meland Budwick, P.A. (“Local Counsel”), who is qualified to practice in

this court, as local counsel for the Client. I understand that Local Counsel is required to

participate in the preparation and the presentation of the case above and any adversary

proceedings in which I appear on behalf of Client, and accept service of all papers served in such

case and proceedings, unless and until other local counsel is designated and accepts such

designation by filing a separate Motion to Appear Pro Hac Vice on my behalf.

I certify that I am familiar with and shall and shall be governed by the local rules of this 

court, the rules of professional conduct and all other requirements governing the professional 

behavior of members of the Florida Bar. 

[REMIANDER OF PAGE INTENTIONALLY LEFT BLANK] 

Chapter 11

EXHIBIT A

Case 21-13797-SMG Doc 26 Filed 04/22/21 Page 4 of 9
{02605097.DOC.} 

I declare under penalty of perjury that the foregoing is true and correct. Executed on 

April 22, 2021. 

Abigail O’Brient, Esq. 

Mintz, Levin, Cohn, Ferris, Glovsky 

and Popeo, P.C. 

Century Plaza Towers 

2029 Century Park East, Suite 3100 

Los Angeles, CA 90067 

T: 310-586-3200 

Email: AOBrient@mintz.com

California Bar No. 265704 

BY:________________________________ 

Case 21-13797-SMG Doc 26 Filed 04/22/21 Page 5 of 9
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UNITED STATES BANKRUPTCY COURT 

SOUTHERN DISTRICT OF FLORIDA 

FT. LAUDERDALE DIVISION 

www.flsb.uscourts.gov

In re: 

LIBERTY POWER HOLDINGS, LLC, Case No.: 21-13797-SMG 

Chapter 11 

 Debtor. 

____________________________________/ 

ORDER ADMITTING ATTORNEY PRO HAC VICE

This matter came before the court upon the Motion to Appear Pro Hac Vice [ECF No. 

__]. The court having reviewed the motion and good cause appearing, it is 

ORDERED that 

1. Abigail O’Brient, Esq. (“Visiting Attorney”) may appear before this court pro hac

vice as counsel for Liberty Power Corp., LLC (the “Client”) in this case where Visiting 

Attorney appear on behalf of Client, subject to the local rules of this court. Visiting Attorney 

shall include the certification required by Local Rule 9011-4(B)(2) in all papers filed with this 

court. 

2. Visiting Attorney may apply to become a registered user of CM/ECF in this

EXHIBIT B

Case 21-13797-SMG Doc 26 Filed 04/22/21 Page 6 of 9
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district with full filing privileges in this case and in any other case in which this court has entered 

an order admitting Visiting Attorney pro hac vice. 

3. The following attorney (“Local Attorney”) is designated as the attorney qualified 

to practice in this court with whom the court and other counsel may readily communicate and 

upon whom papers may be served:

Daniel N. Gonzalez, Esquire 

Fla. Bar No. 938777 

dgonzalez@melandbudwick.com

MELAND BUDWICK, P.A. 

3200 Southeast Financial Center 

200 South Biscayne Boulevard 

Miami, Florida 33131 

Telephone: (305) 358-6363 

Facsimile: (305) 358-1221 

Local Attorney shall act as the local attorney as required by Local Rule 2090-1(C)(2) in 

this case and in each adversary proceeding in this case in which the Visiting Attorney appear on 

behalf of the Client. If Local Attorney declines to serve as the local attorney in any such 

adversary proceeding, a separate local attorney must file an additional Motion to Appear Pro 

Hac Vice, and absent such separate motion and an order of this court approving the same Local 

Attorney will continue to act as local attorney for the Client in all such proceedings. 

### 

Case 21-13797-SMG Doc 26 Filed 04/22/21 Page 7 of 9
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Submitted by: 

Daniel N. Gonzalez, Esquire 

Florida Bar No. 938777 

dgonzalez@melandbudwick.com

MELAND BUDWICK, P.A. 

3200 Southeast Financial Center 

200 South Biscayne Boulevard 

Miami, Florida 33131 

Telephone: (305) 358-6363 

Telecopy: (305) 358-1221 

Local Counsel for Liberty Power Corp., LLC 

Copies furnished to: 

Daniel N. Gonzalez, Esq., is directed to serve copies of the Order on all parties in interest and to 

file a Certificate of Service. 

Case 21-13797-SMG Doc 26 Filed 04/22/21 Page 8 of 9
Exhibit 1 

Mailing Information for Case 21-13797-SMG 

Electronic Mail Notice List

The following is the list of parties who are currently on the list to receive email notice/service 

for this case. 

 Scott Andron sandron@broward.org, swulfekuhle@broward.org 

 Paul J. Battista pbattista@gjb-law.com, gjbecf@gjb-law.com;chopkins@gjblaw.com;jzamora@gjb-law.com;gjbecf@ecf.courtdrive.com;vlambdin@gjb-law.com 

 Daniel N Gonzalez dgonzalez@melandbudwick.com, 

ltannenbaum@melandbudwick.com;mrbnefs@yahoo.com;gonzalez@ecf.courtdrive.com;

ltannenbaum@ecf.courtdrive.com;phornia@ecf.courtdrive.com 

 Jordi Guso jguso@bergersingerman.com, 

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

 Heather L Harmon HHarmon@gjb-law.com, gjbecf@gjblaw.com;ecastellanos@gjb-law.com;gjbecf@ecf.courtdrive.com;jzamora@gjb-law.com 

 Office of the US Trustee USTPRegion21.MM.ECF@usdoj.gov 

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