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UNITED STATES BANKRUPTCY COURT

SOUTHERN DISTRICT OF FLORIDA

Miami-Dade Division

In re: Case No.: 21-14020-RAM

A & S ENTERTAINMENT, LLC

dba The Office

_________________________________________/

OBJECTION TO CLAIMS

IMPORTANT NOTICE TO CREDITOR:

THIS IS AN OBJECTION TO YOUR CLAIM

This objection seeks either to disallow or 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 service of this objection, 

explaining why your claim should be allowed as presently filed, and you must serve 

a copy to the undersigned attorney OR YOUR CLAIM MAY 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.

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

with the Clerk of the United States Bankruptcy Court.

Pursuant to Bankruptcy Rule 3007 and Local Rule 3007-1, the Debtor objects to the 

following claims filed in this case”.

Claim Amount of Basis for Objection and

No Name of Claimant Claim Recommended Disposition

6. CRSJ, Inc. $215,510.00 This claim was filed by the Debtor’s 

Landlord. The Debtor disputes the

amount sought in this claim in that it 

does not reflect any possible amount 

Case 21-14020-RAM Doc 88 Filed 09/24/21 Page 1 of 3
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due to the Landlord, pursuant to the 

indemnification terms of the lease of 

non-residential real property. The 

Landlord seems to take the position that 

all fees, expenses and settlements in 

which it entered is somehow due from 

the Debtor. This assertion is incorrect 

under Florida Law and the Debtor 

objects to the allowance of this claim in 

any amount.

RECOMMENDATION: disallow claim

7. Christopher Nealy $250,000.00 This claim was filed as an unsecured 

claim. The Debtor objects to the 

allowance of the claim in any amount as 

the claim is disputed, contingent and 

unliquidated and should be disallowed in 

this matter. To the extent there is 

insurance which covers this claim, the 

claimant should be allowed to proceed 

against the insurance company.

RECOMMENDATION: disallow claim.

8. Allen Pinder $250,000.00 This claim was filed as an unsecured 

claim. The Debtor objects to the 

allowance of the claim in any amount as 

the claim is disputed, contingent and 

unliquidated and should be disallowed in 

this matter. To the extent there is 

insurance which covers this claim, the 

claimant should be allowed to proceed 

against the insurance company.

RECOMMENDATION: disallow claim.

9. Guy Benoit $250,000.00 This claim was filed late as an 

unsecured claim. 

RECOMMENDATION: Allowed as a 

late-filed Proof of Claim.

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that I am admitted to the Bar of the United States District 

Court of the Southern District of Florida, that I am in compliance with the additional 

qualifications to practice in this Court set forth in Local Rule 2090-1(A) and that a true and

correct copy of the foregoing was filed using CM/ECF and served on September 24, 2021: 

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(i) via CM/ECF upon all parties registered to receive Notice(s) of Electronic Filing (NEF) 

in this bankruptcy case and (ii) via First Class U.S. Mail on the parties on the attached 

Service List.

Moffa & Bierman

Attorneys for the Debtor-In-Possession

3081 E Commerical Blvd., Suite 204

Fort Lauderdale, FL 33308

Telephone 954-634-4733

FAX 954-337-0637

E-Mail: john@moffa.law

By: /s/ John A. Moffa

John A. Moffa

FBN 0932760

Service List

CRSJ, Inc.

18320 NE 1st Court

Miami, FL 33179

Christopher Nealy

c/o Reginald A. Mathis, Esq.

Reginald A. Mathis, LLC

303 SW 6th St., FL 3 PH East

Fort Lauderdale, FL 33315-1027

Allen Pinder

c/o Reginald A. Mathis, Esq.

Reginald A. Mathis, LLC

303 SW 6th St., FL 3 PH East

Fort Lauderdale, FL 33315-1027

Guy Benoit

c/o David Nunez

135 San Lorenzo Ave., Suite 620

Coral Gables, FL 33145

Case 21-14020-RAM Doc 88 Filed 09/24/21 Page 3 of 3