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UNITED STATES BANKRUPTCY COURT

SOUTHERN DISTRICT OF FLORIDA

Miami-Dade Division

In re: Case No.: 21-14020-RAM

A & S ENTERTAINMENT, LLC

dba The Office

_________________________________________/

OBJECTION TO CLAIMS

IMPORTANT NOTICE TO CREDITOR:

THIS IS AN OBJECTION TO YOUR CLAIM

This objection seeks either to disallow or reduce the amount or change the priority

status of the claim filed by you or on your behalf. Please read this objection 

carefully to identify which claim is objected to and what disposition of your claim is 

recommended.

If you disagree with the objection or the recommended treatment, you must file a 

written response WITHIN 30 DAYS from the date of service of this objection, 

explaining why your claim should be allowed as presently filed, and you must serve 

a copy to the undersigned attorney OR YOUR CLAIM MAY BE DISPOSED OF IN 

ACCORDANCE WITH THE RECOMMENDATION IN THIS OBJECTION.

If your entire claim is objected to and this is a chapter 11 case, you will not have 

the right to vote to accept or reject any proposed plan of reorganization until the 

objection is resolved, unless you request an order pursuant to Bankruptcy Rule 

3018(a) temporarily allowing your claim for voting purposes.

The written response must contain the case name, case number, and must be filed 

with the Clerk of the United States Bankruptcy Court.

Pursuant to Bankruptcy Rule 3007 and Local Rule 3007-1, the Debtor objects to the 

following claims filed in this case”.

Claim Amount of Basis for Objection and

No Name of Claimant Claim Recommended Disposition

2. Lee Athill $500,000.00 This claim was filed as an unsecured

claim. The Debtor objects to the 

allowance of the claim in any amount as 

the claim is disputed, contingent and 

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unliquidated and should be disallowed in 

this matter. To the extent there is 

insurance which covers this claim, the 

claimant should be allowed to proceed 

against the insurance company.

RECOMMENDATION: disallow claim 

3. Tanice Athill $500,000.00 This claim was filed as an unsecured 

claim. The Debtor objects to the 

allowance of the claim in any amount as 

the claim is disputed, contingent and 

unliquidated and should be disallowed in 

this matter. To the extent there is 

insurance which covers this claim, the 

claimant should be allowed to proceed 

against the insurance company.

RECOMMENDATION: disallow claim.

4. AIG Property $00.00 This claim was filed as an unsecured 

claim. The Debtor objects to it as it is

unliquidated and further discussions with 

the creditor revealed that no amount is 

due. 

RECOMMENDATION: disallow claim.

5. Kelsie Blash $10,000,000.00 This claim was filed as an unsecured 

claim. The Debtor objects to the 

allowance of the claim in any amount as 

the claim is disputed, contingent and 

unliquidated and should be disallowed in 

this matter. To the extent there is 

insurance which covers this claim, the 

claimant should be allowed to proceed 

against the insurance company.

RECOMMENDATION: disallow claim.

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that I am admitted to the Bar of the United States District 

Court of the Southern District of Florida, that I am in compliance with the additional 

qualifications to practice in this Court set forth in Local Rule 2090-1(A) and that a true and 

correct copy of the foregoing was filed using CM/ECF and served on September 24, 2021: 

(i) via CM/ECF upon all parties registered to receive Notice(s) of Electronic Filing (NEF) 

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in this bankruptcy case and (ii) via First Class U.S. Mail on the parties on the attached 

Service List.

Moffa & Bierman

Attorneys for the Debtor-In-Possession

3081 E Commerical Blvd., Suite 204

Fort Lauderdale, FL 33308

Telephone 954-634-4733

FAX 954-337-0637

E-Mail: john@moffa.law

By: /s/ John A. Moffa

John A. Moffa

FBN 0932760

Service List

Lee Athill

3320 NW 17th Court

Lauderhill, FL 33311

Tanice Athill

3320 NW 17th Court

Lauderhill, FL 33311

AIG Property Casualty, Inc.

Kevin J. Larner, authorized rep.

80 Pine Street, 13th Floor

New York, NY 10005

Kelsie Blash

c/o Bartlett Legal, PLLC

201 S Biscayne Blvd.,

28th Floor

Miami, FL 33131

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