UNITED STATES BANKRUPTCY COURT 

SOUTHERN DISTRICT OF FLORIDA 

FORT LAUDERDALE DIVISION 

www.flsb.uscourts.gov

In re: Chapter 11 Cases 

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

LPT, LLC, Case No. 21-15537-SMG 

LIBERTY POWER MARYLAND, LLC, Case No. 21-15539-SMG 

LIBERTY POWER DISTRICT OF Case No. 21-15540-SMG 

COLUMBIA, LLC, 

 (Jointly administered 21-13797-SMG) 

 / 

AGREED ORDER RESOLVING DEBTORS’ OBJECTION TO CLAIM 

FILED BY JASON MENDOZA ON BEHALF OF HIMSELF AND FORMER 

EMPLOYEES OF THE DEBTOR FOR WARN ACT AND OTHER DAMAGES 

(Claim No. 4 filed in Case No. 21-13797) 

 THIS CAUSE having come before the Court upon Liberty Power Holdings, LLC’s 

Objection to Claim Filed by Jason Mendoza on Behalf of Himself and Former Employees of the 

Debtor for WARN Act and Other Damages [ECF No. 903] (“Objection”) with respect to Claim 

No. 4 (Case No. 21-13797) (the “Claim”) filed as a priority wage claim in the amount of 

$1,000,000 by Jason Mendoza (“Claimant”) on behalf of himself and former employees of the 

Debtor (collectively, the “Purported Class”) for WARN Act and other damages. No class has been 

Scott M. Grossman, Judge

_____________________________________________________________________________ United States Bankruptcy Court

ORDERED in the Southern District of Florida on June 14, 2023.

Case 21-13797-SMG Doc 933 Filed 06/14/23 Page 1 of 3
certified in this matter. The Court, having been informed that the above-captioned Debtors 

(collectively, the “Debtors”) and Claimant have agreed to the relief set forth herein, and finding 

that the relief is in the best interests of the Debtors, their estates and creditors, and being otherwise 

fully advised in the premises, it is: 

ORDERED as follows: 

1. The Objection is resolved as set forth herein. 

2. Claim No. 4 filed in Case No. 21-13797 shall be allowed as a Class 1 Allowed 

Other Priority Claim1

 and, subject to confirmation of the Plan and the occurrence of the Effective 

Date, shall be an Agreed Senior Claim, in the amount of $15,500. The balance of Claim No. 4 is 

stricken and disallowed. 

3. This Order shall constitute a full and final resolution of any and all of the disputes 

or potential disputes and claims by and between Claimant and the Debtors. 

4. Claimant shall be bound by all provisions of the Plan, including, but not limited to, 

all exculpation and releases. However, for avoidance of doubt, nothing contained herein shall 

affect Claimant’s or putative Class member’s rights and claims in the proceeding entitled In re 

Liberty Power Corp., LLC, assignee, Case No. CACE-21-10056 (17th Judicial Circuit, Broward 

County, FL 2021). 

5. The Court shall retain jurisdiction with respect to all matters arising from or related 

to the interpretation, implementation, or enforcement of the terms and provisions of this Order and 

1 All capitalized terms not otherwise defined herein shall have the meaning set forth in the Debtors’ Joint Chapter 

11 Plan of Liquidation Proposed By Liberty Power Holdings, LLC, LPT, LLC, Liberty Power Maryland, LLC and 

Liberty Power District of Columbia, LLC [ECF No. 875] (as may be amended, supplemented, or otherwise modified 

from time to time, the “Plan”). 

Case 21-13797-SMG Doc 933 Filed 06/14/23 Page 2 of 3
to adjudicate, if necessary, all disputes in connection herewith. 

### 

Submitted by: 

Heather L. Harmon, Esq. 

VENABLE LLP 

Attorneys for Debtors-in-Possession 

100 Southeast Second Street, 44th Floor 

Miami, Florida 33131 

Telephone: (305) 349 2300 

Facsimile: (305) 349 2310 

hlharmon@venable.com 

Copies to: 

Heather L. Harmon, Esq. 

[Attorney Harmon shall forward a conformed copy of this Order to all interested parties.] 

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