UNITED STATES BANKRUPTCY COURT

SOUTHERN DISTRICT OF FLORIDA

FORT LAUDERDALE DIVISION

In re: §

§

LIBERTY POWER HOLDINGS, LLC, § CASE NO. 21-13797-SMG

§

DEBTOR. § CHAPTER 11

NOTICE OF APPEARANCE OF THE STATE OF TEXAS AND REQUEST

FOR SERVICE OF PAPERS

PLEASE TAKE NOTICE that the attorney set forth below hereby appears as counsel for 

the State of Texas, by and through the Office of the Attorney General of Texas, pursuant to Rule 

9010 of the Federal Rules of Bankruptcy Procedure (the “Bankruptcy Rules”) and Local Rule 

2090-1(C)(3). The undersigned requests that all notices given or required to be given in the abovecaptioned case (including, but not limited to, all papers filed and served in all adversary 

proceedings in such case, and to creditors and equity security holders who file with the Court) be 

mailed to and served on the following:

Abigail R. Ryan

Rachel R. Obaldo

Assistant Attorneys General

Office of the Attorney General of Texas

Bankruptcy & Collections Division

P. O. Box 12548- MC 008

Austin, Texas 78711-2548

Phone: (512) 463-2173

Fax: (512) 936-1409

PLEASE TAKE FURTHER NOTICE that this request includes not only the notices and 

papers referred to in the Bankruptcy Rules specified above, but also includes, without limitation, 

all orders and notices of any application, motion, petition, pleading, request, complaint, or demand, 

statement of affairs, operating reports, schedules of assets and liabilities, whether formal or 

informal, whether written or oral, and whether transmitted or conveyed by mail, courier service, 

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hand delivery, telephone, facsimile transmission, or otherwise that (1) affects or seeks to affect in 

any way any rights or interest of any creditor or party in interest in this case, with respect to the 

(a) debtor, (b) property of the debtor’s estate, or proceeds thereof, in which the debtor may claim 

an interest, or (c) property or proceeds thereof in the possession, custody, or control of others that 

the debtor may seek to use, or (2) requires or seeks to require any act, delivery of any property, 

payment or other conduct by the undersigned.

[Remainder of Page Intentionally Left Blank]

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Dated: April 23, 2021 Respectfully submitted,

KEN PAXTON 

Attorney General of Texas 

BRENT WEBSTER 

First Assistant Attorney General 

GRANT DORFMAN 

Deputy First Assistant Attorney General 

NANETTE DINUNZIO 

Associate Deputy Attorney General for Civil 

Litigation 

PAUL SINGER 

Senior Counsel for Public Protection

RACHEL R. OBALDO

Assistant Attorney General

Chief, Bankruptcy & Collections Division

/s/ Abigail R. Ryan

ABIGAIL R. RYAN

Texas State Bar No. 24035956

RACHEL R. OBALDO

Texas State Bar No. 24041617

Office of the Attorney General of Texas

Bankruptcy & Collections Division

P. O. Box 12548 MC008

Austin, Texas 78711-2548

Telephone: (512) 463-2173

Facsimile: (512) 936-1409

abigail.ryan@oag.texas.gov

Rachel.obaldo@oag.texas.gov

ATTORNEYS FOR THE STATE OF TEXAS

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CERTIFICATE OF SERVICE

I certify that a true and correct copy of the foregoing has been served via the Court’s 

Electronic Filing System on all parties requesting notice in this proceeding on April 23, 2021.

/s/ Abigail R. Ryan

ABIGAIL R. RYAN

Assistant Attorney General 

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