Notice of Appearance by TCPA Plaintiffs No. 21-13797-SMG 

IN THE UNITED STATES BANKRUPTCY COURT 

FOR THE SOUTHERN DISTRICT OF FLORIDA 

LAUDERDALE DIVISION 

In re LIBERTY POWER HOLDINGS, 

LLC, 

 Debtor. /

No. 21-13797-SMG 

Chapter 11 

NOTICE OF APPEARANCE AND REQUEST FOR SERVICE OF PAPERS

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

Samuel Katz and Lynne Rhodes (“TCPA Plaintiffs”) under Rule 9010(b) of the Federal Rules of 

Bankruptcy Procedure and Local Rule 2090-1(C)(1). All parties are requested to take notice of 

this appearance and serve copies of any and all pleadings, notices, papers, or other document or 

communication that concerns this case and proceedings therein, or that affects or seeks to affect 

in any way any rights or interests of any party in interest in this case on this counsel, under 

section 1109(b) of the Bankruptcy Code and Bankruptcy Rules 2002, 9007 and 9010. This 

request extends to any document or paper requested by and provided to any other party under 

their notice of appearance. (Cf. ECF No. 16, 20, 32 to 34.) 

Ethan Preston 

ep@eplaw.us 

PRESTON LAW OFFICES 

4054 McKinney Avenue, Suite 310 

Dallas, Texas 75204 

Telephone: (972) 564-8340 

Facsimile: (866) 509-1197 

 PLEASE TAKE FURTHER NOTICE that, neither this Notice nor any subsequent 

appearance, pleading, claim or suit is intended or shall be deemed a waiver of any of Rhodes’s 

rights (i) to have final orders in non-core matters entered only after de novo review by a United 

States District Court; (ii) to trial by jury in any proceeding so triable in this case, controversy, or 

proceeding related hereto; (iii) to have the United States District Court withdraw the reference in 

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Notice of Appearance by TCPA Plaintiffs No. 21-13797-SMG 

any matter subject to mandatory or discretionary withdrawal; (iv) to object to any jurisdiction of 

this Court for any purpose other than with respect to this Notice; or (v) to any rights, claims, 

actions, defenses, setoffs, recoupments or remedies to which the Creditor is or may be entitled 

under agreements, in law or in equity, all of which rights, claims, actions, defenses, setoffs, 

recoupments and remedies are expressly reserved. 

Dated: April 26, 2021 By: s/Ethan Preston 

Ethan Preston 

Texas State Bar No. 24091084 

ep@eplaw.us

PRESTON LAW OFFICES 

4054 McKinney Avenue, Suite 310 

Dallas, Texas 75204 

Telephone: (972) 564-8340 

Facsimile: (866) 509-1197 

Attorneys for Plaintiffs Samuel Katz and Lynne 

Rhodes, on their own behalf, and behalf of all 

others similarly situated

 

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Notice of Appearance by TCPA Plaintiffs No. 21-13797-SMG 

CERTIFICATE OF SERVICE 

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

date below, by electronic transmission through the Court’s CM/ECF system upon all parties 

listed below on the CM/ECF Service List and who receives a Notice of Electronic Filing for this 

document. 

Dated: April 26, 2021 By: s/Ethan Preston 

Ethan Preston 

Texas State Bar No. 24091084 

ep@eplaw.us

PRESTON LAW OFFICES 

4054 McKinney Avenue, Suite 310 

Dallas, Texas 75204 

Telephone: (972) 564-8340 

Facsimile: (866) 509-1197 

Attorneys for Plaintiffs Samuel Katz and Lynne 

Rhodes, on their own behalf, and behalf of all 

others similarly situated

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