UNITED STATES BANKRUPTCY COURT 

SOUTHERN DISTRICT OF FLORIDA 

Fort Lauderdale Division 

www.flsb.uscourts.gov

In re: Chapter 11 

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

 Debtor. 

______________________________/ 

DEBTOR’S EMERGENCY MOTION FOR ENTRY OF INTERIM AND FINAL 

ORDERS (I) AUTHORIZING MAINTENANCE OF CERTAIN EXISTING BANK 

ACCOUNTS AND CASH MANAGEMENT SYSTEM, (II) WAIVING CERTAIN U.S. 

TRUSTEE REQUIREMENTS IN CONNECTION THEREWITH, AND 

(III) GRANTING RELATED RELIEF 

(Emergency Interim Hearing Requested on April 27, 2021 at 2:30 p.m.) 

 

Statement of Exigent Circumstances 

The Debtor seeks to continue to operate its business in the ordinary course and 

in connection therewith use its existing pre-petition bank accounts at JP Morgan 

Chase Bank, N.A. The United States Trustee Guidelines require the immediate 

closing of all pre-petition bank accounts and the establishment of new debtor-inpossession accounts. The Debtor receives a large percentage of its customer 

payments via direct deposit/ACH, thereby necessitating the need to keep those 

bank accounts open to streamline operations and facilitate receipt of revenue 

from its customers. Further, the Debtor pays its many of its major creditor 

constituencies via ACH. Lastly, the Debtor granted a lien on such bank 

accounts to its senior secured lender through certain deposit control agreements. 

Therefore, requiring the Debtor to close and change its existing bank accounts at 

this critical juncture would disrupt the Debtor’s cash management system, 

adversely affect the Debtor’s business, and jeopardize its ability to reorganize. 

Therefore, the Debtor seeks authority to maintain its existing pre-petition bank 

accounts in order to ensure the continued cash flow for payment of operating 

expenses and to facilitate its reorganization. 

 

LIBERTY POWER HOLDINGS, LLC (the “Debtor”), by and through its proposed 

undersigned counsel, requests that the Court enter an interim and final Orders (A) authorizing the 

Debtor (i) to maintain its existing Bank Accounts and Cash Management System (each as 

defined below), (ii) to continue its use of Automated Clearing House (“ACH”) transfers and wire 

Case 21-13797-SMG Doc 41 Filed 04/26/21 Page 1 of 14
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transfers for payment of expenses, (iii) to maintain in place any and all deposit control 

agreements on such Bank Accounts, and (iv) to continue to maintain, service and administer the 

Bank Accounts in the ordinary course of business; and (B) waiving the U.S. Trustee 

Requirements in connection therewith (the “Motion”). In connection therewith, the Debtor 

respectfully represents as follows: 

I. JURISDICTION AND VENUE 

1. This Court has jurisdiction over this matter pursuant to 28 U.S.C. §§ 157 and 

1334. This is a core proceeding pursuant to 28 U.S.C. § 157(b). 

2. Venue is proper pursuant to 28 U.S.C. §§ 1408 and 1409. 

3. The statutory predicates for the relief requested herein are sections 105(a) and 

363(c) of title 11 of the United States Code (the “Bankruptcy Code”), Rule 6003 of the Federal 

Rules of Bankruptcy Procedure (the “Bankruptcy Rules”), and Local Rules 9013-1 (J) and 9075-

1. 

II. BACKGROUND 

4. On April 20, 2021 (the “Petition Date”), the Debtor filed a voluntary petition in 

this Court for relief under the Bankruptcy Code (the “Chapter 11 Case”). Since that time, the 

Debtor has operated as a debtor-in-possession pursuant to Sections 1107 and 1108 of the 

Bankruptcy Code. 

5. As of the date hereof, no creditors’ committee has been appointed in this case. In 

addition, no trustee or examiner has been appointed. 

6. For a detailed description of the Debtor and its operations, the Debtor respectfully 

refers the Court and parties in interest to the Declaration of Bob Butler, Proposed Chief 

Restructuring Officer of the Debtor, in Support of Chapter 11 Petition and First Day Motions

Case 21-13797-SMG Doc 41 Filed 04/26/21 Page 2 of 14
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[Docket No. 10] (the “First Day Declaration”) filed April 21, 2021. 

III. CASH MANAGEMENT SYSTEM 

 A. Bank Accounts 

7. Prior to the Petition Date, the Debtor used a cash management system in the 

ordinary course of its business (the “Cash Management System”) so as to efficiently collect, 

transfer, and disburse funds generated by its business operations. As more fully described below 

and in the Bank Account Structure schematic attached hereto as Exhibit “A”, the Debtor has 

five (5) bank accounts at JP Morgan Chase Bank, N.A. (“JP Morgan”) (collectively, the “Bank 

Accounts”).1 JP Morgan is an authorized depository pursuant to the United States Trustee’s 

Authorized Depository Listing (“Authorized Depository List”) established for the Southern 

District of Florida. 

8. The Bank Accounts are described in detail on the attached Exhibit “B.” 

9. The Debtor’s customers make payments into the Lockbox Account (x2233) 

through various mediums, including ACH, credit card, paper checks or electronic checks. Those 

customer payments are then swept on a daily basis into the Debtor's Blocked Account (x9780). 

10. Funds in the Blocked Account are then utilized to make payments and sweeps to 

Boston Energy Trading and Marketing (“BETM”), the Debtor’s senior secured lender. In 

addition, BETM has the benefit of certain deposit control agreements on certain of the Bank 

Accounts designated as Blocked Accounts as set forth on Exhibit “B” hereto. The Blocked 

Account also pays miscellaneous bank charges and pays certain expenses via the Operating 

 

1

 As detailed on Exhibit “A”, the Bank Accounts in the name of the Debtor are interspersed with accounts controlled 

by Liberty Power Corp., the Debtor’s parent company (“ParentCo”). While the ParentCo bank accounts are not in 

the name of the Debtor, they are integral to the Debtor’s Cash Management System. However, at this early stage in 

the case, the Debtor is seeking relief with respect to its Bank Accounts only. As the CRO and his team evaluate the 

Debtor’s cash flow needs, this Motion may be updated or revised as necessary. 

Case 21-13797-SMG Doc 41 Filed 04/26/21 Page 3 of 14
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Account (x9199). Certain funds from the Operating Account are also transferred and held in the 

Money Market Account (x3760) as a collateral account for letters of credit.

11. The Debtor also has a bank account dedicated to non-Texas2

 customer deposits 

(x9207).

IV. RELIEF REQUESTED 

12. By this Motion, the Debtor respectfully requests entry of an order (i) authorizing 

the Debtor to maintain its existing Bank Accounts, as well as its Cash Management System 

related thereto; (ii) granting the Debtor a waiver of certain bank account and related requirements 

of the Office of the United States Trustee for the Southern District of Florida (the “U.S. 

Trustee”) to the extent that such requirements are inconsistent with (a) the existing practices 

under its Cash Management System, or (b) any action taken by the Debtor in accordance with 

any order granting this Motion or any other order entered in the Chapter 11 case.

13. The U.S. Trustee has established its Operating Guidelines for Chapter 11 Cases 

for Region 21 (the “Guidelines”) in order to supervise the administration of chapter 11 cases. 

The Guidelines generally require debtors-in-possession to, among other things, (a) close all 

existing bank accounts and open new accounts, including an operating account, a tax account, a 

payroll account, and, if required by the Court, a cash collateral account, (b) obtain checks for all 

debtor-in-possession accounts that have the designation “debtor-in-possession,” and the 

bankruptcy case number, (c) deposit all receipts into and make all disbursements only from the 

approved Debtor in Possession account(s) (“DIP”) (d) deposit to the tax account sufficient funds 

to pay all tax liabilities, (e) deposit all funds into an account with a depository approved by the 

U.S. Trustee, (f) open a new set of books and records as of the Petition Date, (g) use new 

business forms indicating the debtor in possession status of the chapter 11 debtor, and (h) 

Case 21-13797-SMG Doc 41 Filed 04/26/21 Page 4 of 14
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provide consent to the U.S. Trustee to request copies of bank statements and/or supporting 

documentation directly from the Debtor designed banks and other financial institutions 

(collectively, the “Bank(s)”). The U.S. Trustee has these requirements to provide, among other 

things, a clear demarcation between prepetition and postpetition transactions and operations, 

which would, in theory, prevent the inadvertent postpetition payment of a prepetition claim. As 

explained in further detail below, the Debtor seeks a waiver of certain of these requirements in 

this Motion.

A. Continued Use of Corporate Bank Accounts and Cash Management System. 

14. The Debtor respectfully requests authority to maintain its existing Bank Accounts, 

as well as its Cash Management System related thereto, in accordance with its usual and 

customary pre-petition practices to ensure a smooth transition into chapter 11 with minimal 

disruption to operations. The Debtor will agree to comply with the Guidelines to the extent they 

require the opening of new debtor-in-possession payroll and tax accounts at a U.S. Trustee 

authorized depository; new set of post-petition books and records as of the Petition Date, and 

provide consent to the U.S. Trustee to request copies of bank statements and/or supporting 

documentation directly from the banks.

15. The Cash Management System is similar to the cash management systems used 

by other comparably sized retail energy providers to manage cash flow. The Debtor uses its Cash 

Management System in the ordinary course to transfer and distribute funds and to facilitate cash 

monitoring, forecasting, and reporting. The Cash Management System facilitates the timely and 

efficient collection, management, and disbursement of funds. Because of the nature of the 

business and the disruption that would result if the Debtor is forced to close its existing Bank 

Accounts, it is critical that the existing Cash Management System remain in place.

 2

 Deposits for Texas customers are held in an account owned by affiliated non-debtor LPT, LLC. 

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16. Only if the Debtor continues to use the existing Bank Accounts with the same 

account numbers can the transition into chapter 11 be smooth and orderly, causing minimal 

interference with continuing operations and customer relationships. Requiring the Debtor to open 

new accounts and contact all of its customers to redirect payments will be extremely disruptive 

to the Debtor’s operations and may result in the loss of customers. The Debtor requests a waiver 

of the requirements to designate “Debtor-in-Possession” to any checks in its possession. Of 

course, no checks issued prior to the Petition Date are to be honored, except as otherwise 

provided by separate order of this Court. However, as stated above the Debtor either makes all 

payments by credit card or wire transfer from the disbursement accounts and not by check. 

17. By preserving business continuity and avoiding operational and administrative 

paralysis that closing the existing Bank Accounts and opening new ones would necessarily 

create, all parties-in-interest will be best served by maintaining the Bank Accounts and the 

benefits to the Debtor’s estate will be considerable. The existing Bank Accounts are in 

financially stable institutions insured by the FDIC up to the applicable limit and the Debtor 

understands that JP Morgan is already on the U.S. Trustee’s Authorized Depository List to 

maintain debtor in possession accounts. Therefore, the Bank Accounts comply with the 

requirements of section 345(b) of the Bankruptcy Code. Thus, the Debtor believes that any 

funds that are deposited in these Bank Accounts are secure. Further, the Debtor does not have 

any investment accounts, and as such are in compliance with section 345(b) of the Bankruptcy 

Code and substantially in compliance with the Guidelines. Therefore, the Debtor respectfully 

submits that cause exists to continue to allow the Debtor to utilize its existing Bank Accounts.

18. The confusion that would otherwise result during these fragile times could only 

work to the detriment of the Chapter 11 Case. No checks or electronic transfers issued prior to 

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the Petition Date are to be honored, except as otherwise provided by separate order of the Court, 

subject to the terms and conditions set forth in this Motion. The Debtor reserves its rights 

pursuant to section 549 of the Bankruptcy Code with respect to any checks or transfers issued 

prepetition that is inadvertently honored postpetition. The Debtor will continue to maintain 

records respecting all transfers from its Bank Accounts so that all transactions can be ascertained 

after they have occurred.

19. The Cash Management System constitutes an ordinary course, essential business 

practice providing significant benefits to the Debtor including, among other things, the ability to 

(i) control funds, (ii) ensure the availability of funds when necessary, and (iii) reduce costs and 

administrative expenses by facilitating timely and accurate account balance information. Any 

disruption of the Cash Management System could have a severe and adverse impact upon the 

Debtor’s reorganization efforts. 

B. Authorizing the Debtor to Continue Using ACH and Wire Transfers Is 

Warranted. 

20. The Debtor further requests that the Court grant relief from the Guidelines to the 

extent they require the Debtor to make all disbursements by check. In particular, the Guidelines 

require that all receipts and all disbursements of estate funds must be made by check with a 

notation representing the reason for the disbursement. If the ability to conduct transactions by 

debit or wire transfer, or other similar methods is impaired, the day-to-day activities may be 

unnecessarily disrupted, and its estate will incur additional costs. 

C. Authorizing the Banks to Continue to Maintain, Service and Administer the 

Bank Accounts in the Ordinary Course is Warranted. 

21. The Debtor respectfully requests that the Court authorize JP Morgan to continue 

to maintain, service, and administer the Bank Accounts as accounts of the Debtor as debtor in 

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possession, without interruption and in the ordinary course. In this regard, JP Morgan should be 

authorized to receive, process, honor, and pay any and all checks, ACH transfers, and other 

instructions and drafts payable through, drawn, or directed on such Bank Accounts after the 

Petition Date by holders, makers, or other parties entitled to issue instructions with respect 

thereto; provided that any check, draft, or other notification that the Debtor advises JP Morgan to 

have been drawn, issued, or otherwise presented before the Petition Date may be honored by the 

banks only to the extent authorized by order of the Court.

V. BASIS FOR RELIEF REQUESTED 

22. Section 105(a) of the Bankruptcy Code provides that “[t]he court may issue any 

order, process, or judgment that is necessary or appropriate to carry out the provisions of this 

title.” 11 U.S.C. § 105(a). Courts have long recognized that the power granted by section 105(a) 

was expressly meant to be exercised to effectuate the rehabilitation of the debtor. See, e.g., In re 

Ionosphere Clubs, Inc., 98 B.R. 174, 177 (Bankr. S.D.N.Y. 1989) (citing H.R. Rep. No. 595, 

95th Cong., 1st Sess. 16 (1977)). The relief requested in this Motion is critical to the Debtor 

successful reorganization and is justified under section 105(a) especially during this 

unprecedented financial crisis. 

23. Extensive authority supports the relief the Debtor seeks in the Motion. In other 

Chapter 11 cases, courts have recognized that strict enforcement of the United States Trustee 

requirements does not always serve the purposes of a Chapter 11. Accordingly, courts have often 

granted relief from these requirements and replaced them with alternative procedures. See, e.g., 

In re American Purchasing Services, LLC, Case No. 20-23495-SMG (Bankr. S.D. Fla. Dec. 11, 

2020); In re Mercedes Homes, Inc., et al., Case No. 09-11191-BKC-PGH (Bankr. S.D. Fla. Jan. 

29, 2009); In re TOUSA, Inc., et al., Case No. 08-10928-BKC-JKO (Bankr. S.D. Fla. Jan. 31, 

Case 21-13797-SMG Doc 41 Filed 04/26/21 Page 8 of 14
9 

2008); In re Levitt and Sons, LLC, et al., Case No. 07-19845-BKC-RBR (Bankr. S.D. Fla. Nov. 

14, 2007); In re Gemini Air Cargo Logistics, Inc. Case No. 06-10780-BKC-AJC (Bankr. S.D. 

Fla. Mar. 20, 2006) (Order Granting Emergency Motion For Order (1) Authorizing Continued 

Use Of Existing Business Forms And Records; (2) Authorizing Maintenance Of Existing 

Corporate Bank Accounts And Cash Management System; And (3) Extending Time To Comply 

With 11 U.S.C. § 345 Investment Guidelines); In re Fine Air Serv., Corp., Chapter 11 Case No. 

00-18671-75 (Bankr. S.D. Fla. Feb. 7, 2001) (Order Granting Debtor Emergency Motion for 

Order Authorizing (a) Continued Use of Existing Bank Accounts and Business Forms and (b) 

Maintenance of Cash-Management System); In re Kitty Hawk, Inc., Case No. 400-42141-BJH 

(Bankr. N.D. Tex. May 3, 2000) (Order Granting Motion for Order (1) Authorizing Continued 

Use of Existing Business Forms and Records; (2) Authorizing Maintenance of Existing 

Corporate Bank Accounts and Cash Management System; and (3) Extending Time to Comply 

with 11 U.S.C. § 345 Investment Guidelines); In re UAL Corp., Chapter 11 Case No. 02-B-48191 

(Bankr. N.D. Ill., Dec. 9, 2002) (Order Pursuant to Sections 363, 364, 1107, and 1108 of the 

Bankruptcy Code (a) Authorizing (I) Continue Use of Existing Cash Management System, (II) 

Maintenance of Existing Bank Accounts, (III) Continued Use of Existing Business Forms, and 

(IV) Continued Use of Existing Investment Guidelines; and (b) According Superpriority Status to 

Certain Intercompany Claims); In re Atlas Air Worldwide Holdings, Inc., Chapter 11 Case No. 

04-10792-BKC-RAM (Bankr. S.D. Fla. March 26, 2004) (Final Order Granting Emergency 

Motion for Order (1) Authorizing Continued Use of Existing Business Forms and Records; (2) 

Authorizing Maintenance of Existing Corporate Bank Accounts and Cash Management Systems; 

and (3) Extending Time to Comply with 11 U.S.C. § 345 Investment Guidelines); In re Trans 

World Airlines, Inc., Case No. 92-115 (Bankr. D. Del. Jan. 31, 1992) (Order Authorizing 

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Maintenance and Use of Existing Bank Accounts Located Within the United States, Use of 

Existing Business Forms and Use of Investment and Deposit Guidelines).

24. Additionally, section 363(c)(1) of the Bankruptcy Code authorizes the debtor-inpossession to “use property of the estate in the ordinary course of business without notice or a 

hearing.” 11 U.S.C. § 363(c)(1). The purpose of section 363(c)(1) of the Bankruptcy Code is to 

provide a debtor-in-possession with the flexibility to engage in the ordinary course transactions 

required to operate its business without unneeded oversight by its creditors or the Court. Med. 

Malpractice Ins. Ass’n v. Hirsch (In re Lavigne), 114 F.3d 379, 384 (2d Cir. 1997); In re Git-NGo, Inc., 322 B.R. 164, 171 (Bankr. N.D. Okla. 2004); In re Enron Corp., No. 01-16034 

(ALG), 2003 WL 1562202, at *15 (Bankr. S.D.N.Y. Mar. 21, 2003); In re Atlanta Retail, Inc., 

287 B.R. 849, 856 (Bankr. N.D. Ga. 2002); Chaney v. Official Comm. of Unsecured Creditors of 

Crystal Apparel, Inc. (In re Crystal Apparel, Inc.), 207 B.R. 406, 409 (S.D.N.Y. 1997). 

Included within the purview of section 363(c) is a debtor’s ability to continue the “routine 

transactions” necessitated by a debtor’s cash management system. Amdura Nat’l Distrib. Co. 

v. Amdura Corp. (In re Amdura Corp.), 75 F.3d 1447, 1453 (10th Cir. 1996). Accordingly, the 

Debtor seeks authority under section 363(c)(1) of the Bankruptcy Code to continue the 

collection and disbursement of cash pursuant to its Cash Management System described above.

25. The Debtor respectfully submits that it has shown the relief requested in this 

Motion is appropriate and ask that the Court grant all of the relief requested as being in the best 

interests of the estate.

26. The relief requested in this Motion is vital to ensuring the seamless transition into 

bankruptcy. Authorizing the Debtor to maintain its Cash Management System, as outlined 

Case 21-13797-SMG Doc 41 Filed 04/26/21 Page 10 of 14
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herein, will avoid many of the possible disruptions and distractions that could divert the Debtor 

attention from more pressing matters during the initial days of the Chapter 11 Case.

Waiver of Bankruptcy Rule 6004(a) and 6004(h)

27. Given the nature of the relief requested herein, the Debtor respectfully requests a 

waiver of (a) the notice requirements under Bankruptcy Rule 6004(a) and (b) the 14-day stay 

under Bankruptcy Rule 6004(h), to the extent that either rule is applicable.

WHEREFORE, the Debtor respectfully requests that the Court enter an order (i) 

granting this Motion, (ii) authorizing the Debtor to maintain existing Bank Accounts, as well 

as its Cash Management System, (iii) continue using ACH and Wire transfers, (iv) to maintain 

in place any and all deposit control agreements on such Bank Accounts, (v) continue to 

maintain, service and administer the Bank Accounts in the ordinary course of business; (vi) 

waiving U.S. Trustee requirements in connection therewith, and (vii) granting such other and 

further relief as is just and proper.

Dated this 26th day of April, 2021. 

 Respectfully Submitted, 

 GENOVESE JOBLOVE & BATTISTA, P.A. 

Proposed attorneys for Debtor-in-Possession 

100 Southeast Second Street, Suite 4400 

 Miami, Florida 33131 

 Telephone: (305) 349-2300 

 Facsimile: (305) 349-2310 

 By: /s/ Paul J. Battista 

 Paul J. Battista, Esq. 

Florida Bar No. 884162 

pbattista@gjb-law.com 

Mariaelena Gayo-Guitian, Esq. 

Florida Bar No. 813818 

mguitian@gjb-law.com

Heather L. Harmon 

Florida Bar No. 13192 

hharmon@gjb-law.com

Case 21-13797-SMG Doc 41 Filed 04/26/21 Page 11 of 14
Bank Account Structure

C A S H M A N A G E M E N T

9199

“Operating Account”

2233

“Lockbox”

ZBA Account

Customer 

Collections

Payment of Allowed 

Admin Expenses

Legend

Non-LPH Accounts

LPH Accounts

LPC 

Account

9780

“Blocked Account”

Liberty Power 

Corp

Payment of 

Allowed 

Admin 

Expenses

Returned checks, misc. 

charges, etc.

Operating Disbursements

Payments/Sweeps to BETM

Misc. Bank Charges, etc.

Payment for 

Managed Services

Inter-Company Loans 

between LPH and LPC 

Payroll & Benefits

Operating Disbursements

9207

Non-TX 

Customer 

Deposits

3760

Money Market 

Account

Case 21-13797-SMG Doc 41 Filed 04/26/21 Page 12 of 14
Sch. 7.1(m) - 1

Schedule 7.1(m)

Accounts and Related Control Agreements

Account Number ABA Owner Bank and Address Control Agreement Description

3303153760 21000021 Liberty Power 

Holdings LLC

JPMorgan Chase 

Bank, N.A. 

700 N Pearl St, Floor 

15 Dallas TX, 75021

Cash – JPMC Money 

Market -3760

427702233 21000021 Liberty Power 

Holdings LLC

JPMorgan Chase 

Bank, N.A. 

700 N Pearl St, Floor 

15 Dallas TX, 75021

Blocked Account Control Agreement for 

account number x2233, dated as of July __, 

2020 by and among Liberty Power Holdings 

LLC, Boston Energy Trading and Marketing 

LLC and JPMorgan Chase Bank, N.A.

Cash JPMC - LPH 

Lockbox – Blocked 2233

790509780 21000021 Liberty Power 

Holdings LLC

JPMorgan Chase 

Bank, N.A. 

700 N Pearl St, Floor 

15 Dallas TX, 75021

Blocked Account Control Agreement for 

account number x9780, dated as of July __, 

2020 by and among Liberty Power Holdings 

LLC, Boston Energy Trading and Marketing 

LLC and JPMorgan Chase Bank, N.A.

Cash – JPMC Collateral, 

JPMC 9780

427699199 21000021 Liberty Power 

Holdings LLC

JPMorgan Chase 

Bank, N.A. 

700 N Pearl St, Floor 

15 Dallas TX, 75021

Blocked Account Control Agreement for 

account number x9199, dated as of July 1, 2020

by and among Liberty Power Holdings LLC, 

Boston Energy Trading and Marketing LLC and 

JPMorgan Chase Bank, N.A

Cash – JPMC LPH 

Operating Account 9199

427699207 21000021 Liberty Power 

Holdings LLC

JPMorgan Chase 

Bank, N.A. 

700 N Pearl St, Floor 

15 Dallas TX, 75021

Blocked Account Control Agreement for 

account number x9207, dated as of July __, 

2020 by and among Liberty Power Holdings 

LLC, Boston Energy Trading and Marketing 

LLC and JPMorgan Chase Bank, N.A.

Cash – JPMC –

Customer Deposits 9207

427702548 21000021 LPT, LLC JPMorgan Chase 

Bank, N.A. 

700 N Pearl St, Floor 

15 Dallas TX, 75021

Blocked Account Control Agreement for 

account number x2548, dated as of July __, 

2020 by and among LPT, LLC, Boston Energy 

Cash – JPMC Customer 

Deposits 2548

Case 21-13797-SMG Doc 41 Filed 04/26/21 Page 13 of 14
Sch. 7.1(m) - 2

Trading and Marketing LLC and JPMorgan 

Chase Bank, N.A.

Case 21-13797-SMG Doc 41 Filed 04/26/21 Page 14 of 14