UNITED STATES BANKRUPTCY COURT

SOUTHERN DISTRICT OF FLORIDA

WEST PALM BEACH DIVISION

In re: Case No.:21-17336-MAM 

Chapter 12

ANISA NAZAROVA

Debtor.

/

REQUEST FOR JUDICIAL NOTICE IN SUPPORT OF DEER RUN 

PROPERTY OWNERS’ ASSOCIATION, INC.'S MOTION TO DISMISS

CHAPTER 12 CASE WITH PREJUDICE FOR BAD FAITH FILING AND

FOR ORDER GRANTING PROSPECTIVE RELIEF FROM THE AUTOMATIC STAY

DEER RUN PROPERTY OWNERS' ASSOCIATION, INC. (“Deer Run”), hereby 

requests, pursuant to Rule 201 of the Federal Rules of Evidence and Rule 9017 of the Federal 

Rules of Bankruptcy Procedure, that the Court take judicial notice of Exhibits “A” – “V” attached 

to Deer Run’s Motion to Dismiss Chapter 12 Case with Prejudice for Bad Faith Filing and for 

Order Granting Prospective Relief from the Automatic Stay (the “Motion”) (Doc. 40).

Facts subject to judicial notice include those which "can be accurately and readily 

determined from sources whose accuracy cannot reasonably be questioned." Fed. R. Evid. 

201(b)(2). "The Court must take judicial notice if a party requests it and the Court is supplied with 

the necessary information." Fed. R. Evid. 201(c)(2). Courts regularly take judicial notice of 

undisputed matters of public record, including documents on file in Federal or State Courts. See 

e.g., Beepot v. J.P. Morgan Chase Nat’l Servs. Inc., 57 F. Supp.3d 1358, 1366 (M.D. Fla. 2014) 

(quoting United States v. Jones, 29 F.3d 1549, 1553 (11th Cir. 1994) (holding “a court may take 

notice of another court’s order ... for the limited purpose of recognizing the ‘judicial act’ that the 

order represents or the subject matter of the litigation.”)).

Case 21-17336-MAM Doc 42 Filed 09/20/21 Page 1 of 3
Exhibits “A” – “V” are all documents of public record and include documents on file in 

Federal and State Courts. To the extent Exhibits “A” – “V” include dockets to the federal and state 

court proceedings, Deer Run further requests this Court to take judicial notice of any and all other 

documents on file in those proceedings which have been referenced in the Motion or which the 

Court may determine are appropriate to rely upon in ruling on Deer Run’s Motion.

Deer Run offers Exhibits “A” – “V” in support of Deer Run’s Motion to Dismiss the 

Debtor’s Chapter 12 Case with Prejudice and for in rem Prospective Stay Relief, as these public 

records/filings, along with filings and deficiencies noted on this Court’s docket, illustrate that this 

Chapter 12 case was not a bona fide Chapter 12 petition for relief, but rather another attempt to 

delay, hinder, and/or defraud Deer Run as a Secured Creditor of the Subject Property.

For the foregoing reasons, Deer Run respectfully requests this Court take judicial notice of 

Exhibits “A” through “V” of Deer Run’s Motion to Dismiss Chapter 12 Case (Doc. 38), and all 

such other documents referenced therein, and all such other court filings and public records as the 

Court deems appropriate.

Dated this 20th day of September, 2021.

ROSENBAUM PLLC

Counsel for Deer Run Property Owners’ 

Association, Inc.

250 S. Australian Avenue, 5th Floor

West Palm Beach, FL 33401

Telephone: (561) 653-2900

Email: sbraten@rosenbaumpllc.com

Email: lhenson@rosenbaumpllc.com

By: /s/ Steven R. Braten, Esq._______

Steven R. Braten, Esq.

Florida Bar No. 18074

Case 21-17336-MAM Doc 42 Filed 09/20/21 Page 2 of 3
CERTIFICATE OF SERVICE

I HEREBY CERTIFY that the foregoing has been served electronically this 20th day of 

September 2021 through the Court’s CM/ECF system on all parties on the service list and by U.S. 

mail on the manual service list:

Notice will be electronically mailed to: 

Anisa Nazarova, Debtor

almatovalina@mail.ru (Per Doc. 36)

Michele A Cavallaro on behalf of Creditor Fidelity National Title Group 

michele.cavallaro@fnf.com, andrea.brodsky@fnf.com 

Heidi A Feinman on behalf of U.S. Trustee Office of the US Trustee 

Heidi.A.Feinman@usdoj.gov 

Robert C Furr 

danderson@furrcohen.com, rcf@trustesolutions.net 

Office of the US Trustee 

USTPRegion21.MM.ECF@usdoj.gov 

Hampton Peterson, Esq on behalf of Creditor Palm Beach County Tax Collector 

legalservices@PBCTax.com 

Via US Mail: 

Anisa Nazarova 

d.10 kv.12 Matrosova Street 

Russian Federation, Barda 

Perm area, 618150,

By: /s/ Steven R. Braten, Esq._______

ATTORNEY

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