1 

UNITED STATES BANKRUPTCY COURT 

SOUTHERN DISTRICT OF FLORIDA 

WEST PALM BEACH DIVISION 

www.flsb.uscourts.gov

In Re: CASE NO.: 21-18481-MAM 

Chapter 7 

NITV, LLC 

Debtors. 

___________________________________/

TRUSTEE’S OBJECTION TO CLAIM #1 

IMPORTANT NOTICE TO CREDITORS 

THIS IS AN OBJECTION TO YOUR CLAIM 

This objection seeks either to disallow, or to reduce the amount or change the priority status 

of, the claim filed by you or on your behalf. Please read this objection carefully to identify which 

claim is objected to and what disposition of your claim is recommended. 

If you disagree with the objection or the recommended treatment, you must file a written 

response WITHIN 30 DAYS from the date of this objection, explaining why your claim should be 

allowed as presently filed, and you must mail a copy to the undersigned OR YOUR CLAIM WILL 

BE DISPOSED OF IN ACCORDANCE WITH THE RECOMMENDATION IN THIS 

OBJECTION. 

If your entire claim is objected to and this is a Chapter 11 case, you will not have the right 

to vote to accept or reject any proposed plan of reorganization until the objection is resolved, unless 

you request an order pursuant to Bankruptcy Rule 3018(a) temporarily allowing your claim for 

voting purposes. 

Any written response must contain the case name, case number and must be filed with the 

CLERK OF THE UNITED STATES BANKRUPTCY COURT:

1515 North Flagler Drive, Suite 801, West Palm Beach, FL 33401

Case 21-18481-MAM Doc 54 Filed 12/14/22 Page 1 of 3
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Pursuant to Bankruptcy Rule 3007, MICHAEL R. BAKST, TRUSTEE, objects to the 

following claim filed in this case: 

1. Claim No. 1 filed by Brinkley Morgan, Mark A. Levy, 100 SE Third Avenue, 23rd

Floor, Fort Lauderdale, FL 33394, was filed as an unsecured claim in the amount 

of $327,398.49. The attachment to Claim No. 1 reflects a balance forward as of a 

bill dated October 30, 2008. The Trustee has been in contact with counsel for the 

claimant in an effort to obtain any documentation evidencing that such claim would 

not be time barred. No such evidence has been presented. Accordingly, every 

indication is that the statute of limitations has already expired for this debt. Claim 

No. 1 should be disallowed in its entirety. Further, if any amendment to such 

claim is filed by the claimant without the claimant filing a response to this 

objection, such claim and any amendment to the claim should be disallowed, 

whether or not such amendment is filed before or after an order is entered by the 

Court disallowing the claim. 

WHEREFORE the Trustee has filed his objection to claims and prays the Court grant the 

relief requested. 

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

By regular U.S. Mail to: Brinkley Morgan, Mark A. Levy, 100 SE Third Avenue, 23rd Floor, Fort 

Lauderdale, FL 33394, and to all parties listed below in the manner indicated, on this 14th day of 

December, 2022. 

/s/ Michael R. Bakst 

MICHAEL R. BAKST, TRUSTEE 

Post Office Box 407 

West Palm Beach, Florida 33402 

Telephone: (561) 838-4523 

Email: baksttrustee@gmlaw.com 

Case 21-18481-MAM Doc 54 Filed 12/14/22 Page 2 of 3
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By electronic mail to: 

 Michael R Bakst efilemrb@gmlaw.com, 

ecf.alert+Bakst@titlexi.com;efileu1084@gmlaw.com;efileu1086@gmlaw.com;efileu386

@gmlaw.com;efileu1857@gmlaw.com;efileu3163@gmlaw.com;efileu3214@gmlaw.co

m;efileu3291@gmlaw.com 

 Michael R. Bakst efileu1094@gmlaw.com, 

ecf.alert+bakst@titlexi.com;efileu1092@gmlaw.com;efileu2170@gmlaw.com;efileu386

@gmlaw.com;Melissa.bird@gmlaw.com;efileu2831@gmlaw.com;efileu3214@gmlaw.c

om 

 Eyal Berger eyal.berger@akerman.com, jeanette.martinezgoldberg@akerman.com 

 Julianne R. Frank julianne@jrfesq.com, G59511@notify.cincompass.com 

 Amanda Klopp amanda.klopp@akerman.com, 

jeanette.martinezgoldberg@akerman.com 

 Mark A Levy mark.levy@brinkleymorgan.com, 

sandra.gonzalez@brinkleymorgan.com;brinkleymorganecf@gmail.com 

 Office of the US Trustee USTPRegion21.MM.ECF@usdoj.gov 

 Scott W Zappolo szappolo@zappolofarwell.com 

Manual Notice: 

NITV, LLC 

1210 Breakers West Blvd. 

West Palm Beach, FL 33411-1880 

Brinkley Morgan 

Mark A. Levy 

100 SE Third Avenue 

23rd Floor 

Fort Lauderdale, FL 33394 

Brinkley, Morgan, Solomon, Tatum, 

Stanley, Lunny & Crosby, LLP 

P.O. Box 552 

Fort Lauderdale, FL 33302 

MRB:aml 

29110.0807 

Case 21-18481-MAM Doc 54 Filed 12/14/22 Page 3 of 3