UNITED STATES BANKRUPTCY COURT

SOUTHERN DISTRICT OF FLORIDA 

MIAMI DIVISION

_____________________________________ 

)

In re: )

) Chapter 11 

Mary Brickell Village Hotel, LLC, )

) Case No. 21-17103 (RAM) 

)

 Debtor.1)

_____________________________________ )

CHAPTER 11 CASE MANAGEMENT SUMMARY 

In compliance with Local Rule 2081-1(B), the Debtor-in-Possession, Mary Brickell Village Hotel, 

LLC, files this Chapter 11 Case Management Summary and states: 

1. Date of the Order for Relief (the “Petition Date”): July 21, 2021 

2. Names, case numbers, and dates of filing of related debtors: N/A 

3. Description of the Debtor’s business: The Debtor is the owner of Aloft Miami Brickell, a Marriott 

International hotel brand.

4. Location of the Debtor’s operations and whether the business premises are leased or owned: The 

Debtor’s principal address is 1001 SW 2nd Avenue, Miami, FL 33130. The Debtor owns the 

premises. 

5. Reasons for filing chapter 11: After fallout from COVID-19, dealings with a lender that culminated 

into protracted mortgage foreclosure litigation, and other disputes and litigations, the Debtor 

ultimately turned to chapter 11 to continue operating in the ordinary course, preserve the goingconcern value of its business, dozens of full-time jobs, and to implement a reorganization, through 

which the Debtor intends to exercise its rights to cure any alleged defaults related to the mortgage, 

subject to its legal and equitable arguments for reductions in respect thereof. 

6. List of officers and directors and their salaries and benefits at the time of filing and during the 

1 year prior to filing:  Pedro Villar, on behalf of Manager, ARVI Management Corporation  Jessica L.M. Woodward, Independent Manager 

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 The last four digits of the Debtor’s tax identification number are 7701. The Debtor’s principal address is 1001 

SW 2nd Ave., Miami, FL 33130. 

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7. The Debtor’s fiscal or calendar year to date gross income and the debtor's gross income for the 

calendar or fiscal year prior to the filing of this petition: 

a. 2021 Gross Income to Date: Approximately $3 million through June 30, 2021 

b. 2020 Gross Income: Approximately $3.9 million 

8. Amounts owed to various creditors: 

a. Obligations owed to priority creditors: $289,015.20 

b. Amount of secured claims and description and estimated value of collateral: The Debtor’s 

sole secured creditor is DF VII REIT Holdings, LLC, its mortgage lender. The amount of 

the claim is disputed, but the Debtor estimates the claim amount is approximately 

$17,844,560.00 and the value of the collateral that supports the claim is greater than 

$32,742,182.00 

c. Amount of unsecured claims: The Debtor estimates the total amount of nonpriority 

unsecured claims is $268,803.09. The total amount of unsecured claims (priority and 

nonpriority) is estimated to be $557,818.29. 

9. General description and approximate value of the Debtor’s assets: The Debtor’s principal asset is 

real property in the form of the hotel itself, along with personal property situated thereon and related 

thereto. The Debtor estimates the value of its assets to be at least $33 million. 

10. List of all insurance policies, the property covered under the policy, the name of the insurer, the 

policy number, amount of coverage, whether the premium is current, the date the next premium is 

due and date the policy expires: The Debtor maintains a single, umbrella insurance policy. The 

Debtor is current on its premiums and the policy does not expire until January 31, 2022. The next 

insurance payment is estimated to be in the amount of $10,779.90 and will come due within twentyone (21) days after the Petition Date. 

11. Number of employees and amounts of wages owed as of petition date: approximately 28. 

12. Status of the Debtor’s payroll and sales tax obligations: The Debtor has incurred $26,565.54 in 

prepetition sales taxes, as described in greater detail in the Taxes Motion (as defined herein). The 

Debtor pays payroll taxes in the ordinary course and expects that it has minimal prepetition payroll 

tax liability. A more detailed description of the Debtor’s payroll system is present in the Wages 

Motion (as defined herein). 

13. Anticipated emergency relief to be requested within fourteen (14) days from the Petition Date: 

a. Debtor’s Motion for Entry of Interim and Final Orders (I) Authorizing Use of Cash 

Collateral Pursuant to 11 U.S.C. § 363, (II) Deeming Its Secured Lender Adequately 

Protection Pursuant to 11 U.S.C. §§ 361 and 363, and (III) Scheduling a Final Hearing 

[Docket No. 3] (the “Cash Collateral Motion”);

b. Debtor’s Motion for Entry of Interim and Final Orders (I) Authorizing the Debtor to 

(A) Operate Its Cash Management System, (B) Honor Certain Prepetition Obligations 

Related Thereto, and (C) Maintain Existing Business Forms, (II) Authorizing, but Not 

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Directing the Debtor to (A) Maintain Existing Customer Programs and (B) Honor 

Prepetition Customer Obligations, and (III) Granting Related Relief [Docket No. 4] 

(the “Cash Management Motion”);

c. Amended Debtor’s Motion for Entry of an Order (A) Authorizing the Debtor to (I) Pay 

Prepetition Employee Wages, Salaries, and Other Compensation, and (II) Continue 

Employee Benefits Programs, and (B) Granting Related Relief [Docket No. 6] 

(the “Wages Motion”);

d. Debtor’s Motion for Entry of Interim and Final Orders (I) Authorizing the Payment of 

Certain Prepetition Taxes and Fees and (II) Granting Related Relief [Docket No. 7] 

(the “Taxes Motion”); 

e. Debtor’s Motion for Entry of Interim and Final Orders (I) Authorizing, but Not Directing 

the Debtor to (A) Continue Honoring Its Obligations Under Insurance Policies Entered 

into Prepetition and Satisfy Prepetition Obligations Thereto and (B) Renew, Supplement, 

Modify, or Purchase Coverage, and (II) Granting Related Relief [Docket No. 8] 

(the “Insurance Motion”); and

f. Debtor’s Motion for Entry of an Order (I) Prohibiting Utility Providers from Altering, 

Refusing, or Discontinuing Utility Services, (II) Deeming Utility Providers Adequately 

Assured of Future Performance, (III) Establishing Procedures for Determining Adequate 

Assurance of Payment, and (IV) Granting Related Relief [Docket No. 9] (the “Utilities 

Motion”).

[Signature Page to Follow] 

 

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Dated: July 23, 2021 

Miami, Florida 

Respectfully submitted,

MARY BRICKELL VILLAGE HOTEL, LLC 

Debtor and Debtor-in-Possession 

1001 SW 2nd Avenue 

Miami, Florida 33130

By: /s/ Pedro F. Villar

Pedro F. Villar 

President of ARVI Management Corporation, its 

Manager 

PACK LAW 

Proposed Counsel to the Debtor and Debtor-inPossession 

51 Northeast 24th Street, Suite 108 

Miami, Florida 33137 

Telephone: (305) 916-4500

By: /s/ Joseph A. Pack

Joseph A. Pack 

Email: joe@packlaw.com 

Florida Bar No. 117882 

Jessey J. Krehl 

Email: jessey@packlaw.com 

Florida Bar No. 1025848 

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