UNITED STATES BANKRUPTCY COURT

SOUTHERN DISTRICT OF FLORIDA

MIAMI DIVISION

www.flsb.uscourts.gov

In re: Case No.: 21-16133

OCEANROAD GLOBAL SERVICES LIMITED, Chapter 15

Debtor in a Foreign Proceeding.

_________________________________/

In re: Case No.: 21-16139

HOLDWAVE TRADING LIMITED, Chapter 15

Debtor in a Foreign Proceeding.

_________________________________/

MOTION FOR JOINT ADMINISTRATION UNDER 

FED. R. BANK. P. 1015(b) & LOCAL RULE 1015-1

Nicholas Wood, Colin Diss, and Michael Leeds, the joint liquidators (“Joint Liquidators” 

or “Foreign Representatives”) of the foreign bankruptcy estates of Oceanroad Global Services 

Limited (“Oceanroad”) and Holdwave Trading Limited (“Holdwave”) (collectively, the 

“Debtors”), submit this Motion for Joint Administration for procedural purposes only, under 

Federal Rule of Bankruptcy Procedure 1015 and Local Rule 1015-1, and in support state as 

follows:

BACKGROUND

1. On June 24, 2021, the Foreign Representatives filed two petitions for relief under 

Chapter 15 of the United States Bankruptcy Code. The first-filed case of In re: Oceanroad Global 

Services Limited, Case No. 21-16133, was assigned to The Honorable Laurel M. Isicoff. The case 

of In re: Holdwave Trading Limited, Case No. 21-16139, was filed second and assigned to The 

Honorable Robert A. Mark.

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2. For the reasons stated herein, the two cases are related and therefore should be 

jointly administered.

JURISDICTION

3. This Court has jurisdiction of this matter pursuant to 28 U.S.C. § 157(b)(2)(P), 

Federal Rule of Bankruptcy Procedure 1015, and Local Rule 1015-1. 

BASIS FOR RELIEF

4. The Court may order the joint administration of the estates of a debtor and its 

affiliates for procedural purposes under Federal Rule of Bankruptcy Procedure 1015(b)(4).

5. The Foreign Representatives were appointed as the joint liquidators for the estates 

of both Debtors, as confirmed by the Liquidation and Appointment Orders entered by the High 

Court of Justice Business and Property Courts in Manchester Insolvency and Companies List 

(ChD). See DE 2-1(A).

6. The Foreign Representatives filed two petitions for recognition under Chapter 15 

for the related estates of Oceanroad and Holdwave. As demonstrated by the timeline attached as 

Exhibit 1, these Debtors have had the same shareholders throughout their corporate existence, 

except for a short period from 2008-2011. They also had the same directors during most of their 

corporate existence. Thus, the request for joint administration is proper under Rule 1015.

7. Moreover, the Foreign Representatives expect to serve discovery that will implicate 

both cases. Accordingly, joint administration will save judicial resources, time, and costs and will 

avoid potential confusion and duplicative work in the discovery process, such as the avoidance of 

duplicative notices, as well as any motions, hearings, and orders pertaining thereto. 

8. This Court and other courts have entered orders to jointly administer related 

Chapter 15 cases. See In re Massa Falida de Mappin Lojas de Departamento S.A., Case No. 16-

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25541-RAM, at DE 11 (Bankr. S.D. Fla. 2016); In re Diplomata S/A Industrial E. Comercial, Case 

No. 16-15327-LMI, at DE 9 (Bankr. S.D. Fla. 2016); In re Durant Int’l Corp., Case No. 19-26542-

AJC, at DE 11 (Bankr. S.D. Fla. 2020); see also In re OAS, S.A., No. 15-10937-SMB, at DE 13 

(Bankr. S.D.N.Y. 2015).

9. Under Local Rule 1015-1(A)(1)(b), joint administration will not give rise to conflict 

of interests among the cases being jointly administered. 

NOTICE AND REQUEST FOR HEARING TO BE 

SET WITH RECOGNITION HEARING

10. Since all other foreign proceedings involving these Debtors are being prosecuted 

by the Foreign Representatives and there is no litigation pending in the United States in which the 

Debtors are parties, the Foreign Representatives submit that no further notice of this Motion is 

required. 

11. The Foreign Representatives request that this Court consider the relief requested at 

the same hearing when the Court shall consider the Foreign Representatives’ Verified Motion for 

Order of Recognition of Foreign Main Proceeding. DE 2.

DESIGNATION OF LEAD CASE

12. Finally, pursuant to Local Rule 1015-1(A)(5)(a), the Foreign Representatives

request that Case No.: 21-16133, In re: Oceanroad Global Services Limited, be designated as the 

“lead case” and that the caption for both cases be modified to reflect their joint administration 

under the designated lead case as follows:

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UNITED STATES BANKRUPTCY COURT

SOUTHERN DISTRICT OF FLORIDA

MIAMI DIVISION

www.flsb.uscourts.gov

In re: Case No.: 21-16133

OCEANROAD GLOBAL SERVICES LIMITED, Chapter 15

HOLDWAVE TRADING LIMITED,

Debtors in a Foreign Proceeding. (Jointly Administered)

_________________________________/

WHEREFORE, the Foreign Representatives respectfully request that this Court enter an 

Order granting this Motion for Joint Administration and for such further relief this Court deems 

just and proper.

Date: June 25, 2021 Respectfully submitted,

SEQUOR LAW, P.A.

1111 Brickell Avenue, Suite 1250

Miami, Florida 33131

Telephone: (305) 372-8282 

Facsimile: (305) 372-8202

 By: /s/ Carolina Z. Goncalves

Edward H. Davis, Jr., Fla. Bar No. 704539

edavis@sequorlaw.com

Gregory S. Grossman, Fla. Bar No. 896667

ggrossman@sequorlaw.com

Nyana Abreu Miller, Fla. Bar No. 092903

nmiller@sequorlaw.com

Carolina Z. Goncalves, Fla. Bar No. 124570

cgoncalves@sequorlaw.com

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CERTIFICATE OF SERVICE

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

June 25, 2021 upon all interested parties registered to receive notice via this Court’s CM/ECF 

electronic notification system.

/s/ Carolina Z. Goncalves

Carolina Z. Goncalves

Notice will be electronically mailed to: 

Nyana Abreu Miller on behalf of Debtors Oceanroad Global Services Limited and Holdwave 

Trading Limited

nmiller@sequorlaw.com, msanchez@sequorlaw.com

Carolina Z. Goncalves on behalf of Debtors Oceanroad Global Services Limited and Holdwave 

Trading Limited

cgoncalves@sequorlaw.com, msanchez@sequorlaw.com

Office of the US Trustee 

USTPRegion21.MM.ECF@usdoj.gov

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