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) 

/ 

DEBTORS’ SECOND OMNIBUS OBJECTION TO PRIORITY AND 

ADMINISTRATIVE TAX CLAIMS PAID OR OTHERWISE SATISFIED IN FULL 

PLEASE LOCATE YOUR NAME ON EXHIBIT “A” 

EXHIBIT IS IN ALPHABETICAL ORDER BY STATE OR AGENCY

LIBERTY POWER HOLDINGS, LLC (“Holdings”), LIBERTY POWER DISTRICT 

OF COLUMBIA, LLC (“Liberty District of Columbia”), LPT, LLC (“LPT”) and LIBERTY 

POWER MARYLAND, LLC (“Liberty Maryland”)(collectively, the “Debtors”), by and through 

undersigned counsel, and pursuant to Fed. R. Bankr. P. 3007 and Local Rule 3007-1, files this 

Second Omnibus Objection (“Objection”) to the Proofs of Claim set forth on the attached Exhibit 

“A” (collectively, the “Claims”). 

1. The filing of this Objection does not impair, and is without prejudice to, the 

Debtors’ rights to further object to the Claims on any other grounds or to seek any further or 

additional relief available under the Bankruptcy Code or any other applicable law. 

2. Each of the Claims was paid in full or otherwise satisfied prior to or during these 

Chapter 11 cases. The Debtors seek to strike and disallow the Claims in their entirety. 

WHEREFORE, the Debtors respectfully request that this Court enter an Order: (i) 

sustaining this Objection, (ii) striking and disallowing each of the Claims in its entirety. 

Case 21-13797-SMG Doc 905 Filed 05/25/23 Page 1 of 5
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Dated this 25th day of May, 2023. 

Respectfully Submitted, 

VENABLE, LLP 

Counsel for Debtors-in-Possession 

100 Southeast Second Street, Suite 4400 

Miami, Florida 33131 

Telephone: (305) 349-2300 

Facsimile: (305) 349-2310 

By: /s/ Heather L. Harmon

Paul J. Battista, Esq. 

Florida Bar No. 884162 

pjbattista@venable.com

Mariaelena Gayo-Guitian, Esq. 

Florida Bar No. 813818 

mguitian@venable.com

Heather L. Harmon, Esq. 

Florida Bar No. 13192 

hlharmon@venable.com

Case 21-13797-SMG Doc 905 Filed 05/25/23 Page 2 of 5
Liberty Power Holdings, LLC, et al.

Exhibit "A" to Debtors' Second Omnibus Objection to Claims

Claim Number Debtor State or Agency Creditor Name Claim Type as Filed Claim Amount as Filed Basis for Objection 

92 LPH California

Franchise Tax BoardAttn: Anthony FranklinBankruptcy Section MS A340PO Box 2952Sacramento, CA 95812-2952

Priority Tax 1,114.78 $ 

This Claim has been paid in full or otherwise satisfied in full prior to or during these Chapter 11 Cases.

95 LPH Delaware

State of Delaware Division of RevenueAttn: Christina Rojas820 N. French St.Wilmington, DE 19801christina.rojas@delaware.gov

Priority Tax 49,345.46 $ 

This Claim has been paid in full or otherwise satisfied in full prior to or during these Chapter 11 Cases.

4 LPDC District of Columbia

District of Columbia - Government Office of Tax and RevenueAttn: Angela ColemanPO Box 37559Washington DC 20013angela.coleman@dc.govDistrict of Columbia - Government Office of Tax and RevenueAttn: Eugenia Williams1101 4th Street SWWashington DC 20024eugenia.williams@dc.gov

Priority Tax 7,903.34 $ 

This Claim has been paid in full or otherwise satisfied in full prior to or during these Chapter 11 Cases.

100 LPH Illinois

Illinois Department of RevenueBankruptcy UnitAttn: Patricia KnipferPO Box 19035Springfield, IL 62794REV.Bankruptcy@illinois.gov

GUC Unliquidated

This Claim has been paid in full or otherwise satisfied in full prior to or during these Chapter 11 Cases.

130 LPH IRS

Internal Revenue ServiceAttn: Beatriz AlfaroCity View Plaza II - Insolvency48 Carr 165, Suite #2000Guaynabo, PR 00968-8000beatriz.alfaro@irs.gov

Admin 3,380.74 $ 

This Claim has been paid in full or otherwise satisfied in full prior to or during these Chapter 11 Cases.

7 LPH IRS

Internal Revenue ServiceAttn: Beatriz AlfaroCity View Plaza II - Insolvency48 Carr 165, Suite #2000Guaynabo, PR 00968-8000beatriz.alfaro@irs.gov

Priority Tax Unliquidated

This Claim has been paid in full or otherwise satisfied in full prior to or during these Chapter 11 Cases.

Page 1 of 3

Case 21-13797-SMG Doc 905 Filed 05/25/23 Page 3 of 5
Liberty Power Holdings, LLC, et al.

Exhibit "A" to Debtors' Second Omnibus Objection to Claims

Claim Number Debtor State or Agency Creditor Name Claim Type as Filed Claim Amount as Filed Basis for Objection 

3 LPMD Maryland

Comptroller of the TreasuryAttn: Tria White301 W Preston St., Room #409Baltimore, MD 21201-2383twhite2@marylandtaxes.gov

Priority Tax 72,713.00 $ 

This Claim has been paid in full or otherwise satisfied in full prior to or during these Chapter 11 Cases.

94 LPH Massachusetts

Massachusetts Department of RevenueBankruptcy Unit - Attn: Ciro NjinyahPO Box 9564Boston, MA 02114-9564njinyahc@dor.state.ma.us

Priority Tax 96,871.59 $ 

This Claim has been paid in full or otherwise satisfied in full prior to or during these Chapter 11 Cases.

12 LPH New Jersey

New Jersey Division of TaxationAttn: Stephanie HarlePO Box 245Trenton, NJ 08695Stephanie.Harle@treas.nj.gov

Priority Tax - $ 

This Claim has been paid in full or otherwise satisfied in full prior to or during these Chapter 11 Cases.

132 LPH New Jersey

New Jersey Division of TaxationAttn: Stephanie HarlePO Box 245Trenton, NJ 08695Stephanie.Harle@treas.nj.gov

Admin 706.23 $ 

This Claim has been paid in full or otherwise satisfied in full prior to or during these Chapter 11 Cases.

129 LPH New Jersey

New Jersey Division of TaxationAttn: Stephanie HarlePO Box 245Trenton, NJ 08695Stephanie.Harle@treas.nj.gov

Priority Tax - $ 

This Claim has been paid in full or otherwise satisfied in full prior to or during these Chapter 11 Cases.

122 LPH New York

State of New York Department of Taxation & FinanceBankruptcy SectionPO Box 5300Albany, NY 12205-0300

Admin - $ 

This Claim has been paid in full or otherwise satisfied in full prior to or during these Chapter 11 Cases.

133 LPH New York

State of New York Department of Taxation & FinanceBankruptcy SectionPO Box 5300Albany, NY 12205-0300

Admin 8,886.23 $ 

This Claim has been paid in full or otherwise satisfied in full prior to or during these Chapter 11 Cases.

96 LPH New York

State of New York Department of Taxation & FinanceBankruptcy SectionPO Box 5300Albany, NY 12205-0300

Priority Tax 318,949.14 $ 

This Claim has been paid in full or otherwise satisfied in full prior to or during these Chapter 11 Cases.

Page 2 of 3

Case 21-13797-SMG Doc 905 Filed 05/25/23 Page 4 of 5
Liberty Power Holdings, LLC, et al.

Exhibit "A" to Debtors' Second Omnibus Objection to Claims

Claim Number Debtor State or Agency Creditor Name Claim Type as Filed Claim Amount as Filed Basis for Objection 

13 LPT Texas

Texas Comptroller of Public AccountsAttn: Lydia H HewettBankruptcy & Collections, Div MC-008PO Box 12548Austin, TX 78711-2548Texas Comptroller of Public AccountsAttn: Courtney J. Hull, Esq.Bankruptcy & Collections, Div MC-008PO Box 12548Austin, TX 78711-2548Courtney.Hull@oag.texas.gov

Admin 69,143.08 $ 

This Claim has been paid in full or otherwise satisfied in full prior to or during these Chapter 11 Cases.

Page 3 of 3

Case 21-13797-SMG Doc 905 Filed 05/25/23 Page 5 of 5