1 

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 COLUMBIA, LLC Case No. 21-15540-SMG

Debtors. (Jointly administered 21-13797-SMG) 

/ 

DEBTORS’ JOINT EX-PARTE MOTION FOR ENTRY OF ORDER: (A) 

CONDITIONALLY APPROVING JOINT DISCLOSURE STATEMENT; (B) 

AUTHORIZING SOLICITATION OF VOTES ON JOINT PLAN OF LIQUIDATION; 

(C) APPROVING SOLICITATION PROCEDURES; (D) APPROVING ADDITIONAL 

NOTICE PROCEDURES; AND (E) SCHEDULING A COMBINED HEARING ON 

FINAL APPROVAL OF THE JOINT DISCLOSURE STATEMENT AND HEARING ON 

CONFIRMATION OF THE JOINT PLAN OF LIQUIDATION

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

POWER MARYLAND, LLC (“Liberty MD”) and LIBERTY POWER DISTRICT OF 

COLUMBIA, LLC (“Liberty DC”) (collectively, the “Debtors”), by and through undersigned 

counsel, move ex-parte for entry of an order: (a) conditionally approving the Joint Disclosure 

Statement For Joint Chapter 11 Plan of Liquidation Proposed By Liberty Power Holdings, LLC, 

LPT, LLC, Liberty Power Maryland, LLC and Liberty Power District of Columbia, LLC dated as 

of April 14, 2023 and filed contemporaneously with this Motion [ECF No. 880] (the “Disclosure 

Statement”); (b) authorizing solicitation of votes on the Joint Chapter 11 Plan of Liquidation 

Proposed By Liberty Power Holdings, LLC, LPT, LLC, Liberty Power Maryland, LLC and 

Liberty Power District of Columbia, LLC, dated April 14, 2023 [ECF No. 875] (the “Plan”)1; (c) 

1 Capitalized terms used in this Motion and not otherwise defined herein shall have meanings ascribed to such terms 

in the Plan. 

Case 21-13797-SMG Doc 881 Filed 04/21/23 Page 1 of 26
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approving solicitation procedures for voting on the Plan; (d) approving additional notice 

procedures for parties not eligible to vote on the Plan; and (e) scheduling a combined hearing for 

final approval of the Disclosure Statement and hearing on confirmation of the Plan. In support 

thereof, the Debtors respectfully state as follows:

JURISDICTION AND VENUE

3. On April 20, 2021 (the “Holdings Petition Date”), Holdings filed a voluntary 

petition in this Court for relief under Chapter 11 of Title 11 of the Bankruptcy Code. Since that 

time, Holdings has operated as a debtor-in-possession pursuant to Sections 1107 and 1108 of the 

Bankruptcy Code.

4. On June 4, 2021 (the “Subsidiary Petition Date”), each of Liberty District of 

Columbia, LPT and Liberty MD filed chapter 11 bankruptcy petitions, which bankruptcy cases 

were jointly administered with the chapter 11 case of Holdings, including to facilitate the sale of 

all, or substantially all, of the Debtors’ assets, including without limitation, retail customer 

contracts, pursuant to Sections 363 and 365 of the Bankruptcy Code.

5. As of the date hereof, no creditors’ committee has been appointed in these cases. 

In addition, no trustee or examiner has been appointed.

6. The Debtors are operating their business and managing their affairs as debtors in 

possession pursuant to 11 U.S.C. §§1107(a) and 1108.

7. This Court has jurisdiction over these Chapter 11 cases under 28 U.S.C. §§ 157 

and 1334. This matter constitutes a core proceeding under 28 U.S.C. § 157(b)(2). Venue is 

proper in this District under 28 U.S.C. §§ 1408. 

8. The statutory predicates for the relief requested in this Motion are Bankruptcy 

Code §§ 105, 1125 and 1128 and Rules 2002, 3017, 3018, 3020 and 9006 of the Federal Rules of 

Case 21-13797-SMG Doc 881 Filed 04/21/23 Page 2 of 26
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Bankruptcy Procedure (the “Bankruptcy Rules”) and Local Rules 3017-1, 3018-1, and 3020-1.

RELIEF REQUESTED

9. On April 14, 2023, the Debtors filed the Plan. The Plan contemplates: (a) the 

payment of Allowed Administrative Expense Claims and Allowed Priority Claims (the 

“Unimpaired Unsecured Claims”) from the proceeds of the BETM Settlement (as defined in the 

Plan), (b) the surrender of collateral to all secured creditors (other than BETM) in satisfaction of 

the Secured Claims, and (c) the subordination of BETM’s right to receive a distribution on 

account of its Allowed Superpriority Administrative Expense Claims and its Secured Claims so 

that, subject to the terms of the Plan, the Debtors can pay the Unimpaired Unsecured Claims in 

full, in cash, from the proceeds of BETM’s collateral. All other Classes of Creditors and Equity 

Holders are deemed to have rejected the Plan and the Debtors will not solicit acceptances to the 

Plan from those Classes. Therefore, the Debtors will only solicit acceptances to the Plan f rom 

BETM. 

10. Through this Motion, the Debtors respectfully request that this Court enter an 

Order (the “Disclosure Statement Order”): (a) conditionally approving the Disclosure Statement; 

(b) authorizing solicitation of votes on the Plan; (c) approving solicitation procedures for voting 

on the Plan (the “Solicitation”); (d) approving the form of notice attached hereto as Exhibit A for

holders of Claims and Equity Interests who are not eligible to vote because they are conclusively 

deemed either to have accepted or rejected the Plan pursuant to sections 1126(f) or (g) of the 

Bankruptcy Code (the “Non-Voting Notice”); (e) approving the form of notice attached hereto as 

Exhibit B for parties who are not holders of Claims or Equity Interests (the “Confirmation 

Notice”); and (f) scheduling a combined hearing to consider final approval of the Disclosure 

Statement and hearing for confirmation of the Plan (the “Combined Hearing”). 

11. An accelerated solicitation and confirmation process in respect of the Plan is 

Case 21-13797-SMG Doc 881 Filed 04/21/23 Page 3 of 26
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optimal. The Plan provides for the Distribution of Available Cash on hand on the Effective Date 

from the liquidation of the Debtors’ Assets and settlement of Causes of Actions pursuant to the 

priorities mandated by the Bankruptcy Code. The Debtors believe that the Plan will allow f or a 

prompt conclusion of each Debtor’s Chapter 11 Case. As a result, the Debtors believe that 

proceeding to confirmation on a combined basis is in the best interest of the Debtors’ estates and 

their creditors.

BASIS AND AUTHORITY FOR RELIEF 

A. Conditional Approval of the Disclosure Statement

12. Although this Motion contemplates that the Debtors will seek final approval of 

the Disclosure Statement at the Combined Hearing, the Debtors request that the Court: (i) enter 

the Disclosure Statement Order and conditionally approve the Disclosure Statement as 

containing information sufficient to satisfy section 1125(b) of the Bankruptcy Code, subject to 

final approval at the Combined Hearing; (ii) authorize the Debtors to commence Solicitation of 

votes to accept or reject the Plan as soon as practicable after entry of the Disclosure Statement 

Order; (iii) approve the Non-Voting Notice for those holders of Claims and Equity Interests who

are conclusively presumed either to have accepted or rejected the Plan pursuant to sections 

1126(f) or (g) of the Bankruptcy Code; and (iv) approve the Confirmation Notice for those 

parties who are not holders of Claims or Equity Interests under the Plan. Conditional approval of 

the Disclosure Statement at this time will enable the Debtors to timely commence Solicitation, 

eliminate the need for the scheduling of a separate disclosure statement hearing, shorten the 

length of these Chapter 11 Cases, facilitate the confirmation and consummation of the Plan, and 

reduce administrative expenses.

13. Conditional approval of the Disclosure Statement will not prejudice any creditors. 

The Debtors believe that BETM, who is the only creditor with an impaired claim that is entitled 

Case 21-13797-SMG Doc 881 Filed 04/21/23 Page 4 of 26
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to vote under the Plan, will be able to sufficiently review and assess both the Plan and the 

Disclosure Statement in the amount of time proposed. In addition, the Debtors believe that each 

holder of a Claim or Equity Interest conclusively presumed to have accepted or rejected the Plan

pursuant to sections 1126(f) or (g) of the Bankruptcy Code, and other interested parties who are 

not holders of a Claim or Equity Interest will receive instructions for how to obtain a copy of the 

Plan and Disclosure Statement (at no charge) and adequate notice of the Combined Hearing and 

related deadlines. Furthermore, BETM, as the only creditor entitled to vote on the Plan, will 

receive at least thirty (30) days’ notice of the Combined Hearing and will have the opportunity to 

be heard and to object to the adequacy of the Disclosure Statement prior to its final approval at 

the Combined Hearing.

14. Section 105(a) of the Bankruptcy Code provides the Bankruptcy Court with broad 

authority and discretion to enforce the provisions of the Bankruptcy Code. Section 105(a)

provides that “[t]he court may issue any order, process, or judgment that is necessary or 

appropriate to carry out the provisions of this title.” The broad scope of the Bankruptcy Court’s 

equitable powers is supported by ample authority. See In re American Family Enters., 256 B.R. 

377, 405 (D.N.J. 2000); In re Allegheny Int’l, Inc., 118 B.R. 282, 302 (Bankr. W.D. Pa. 1990).

15. Moreover, section 105(d) of the Bankruptcy Code specifically provides “that the 

hearing on approval of the disclosure statement may be combined with the hearing on 

confirmation of the plan.” 11 U.S.C. § 105(d)(2)(B)(vi). Section 1128(a) of the Bankruptcy 

Code requires that “after notice, the court shall hold a hearing on confirmation of a plan.” 11 

U.S.C. § 1128(a). Bankruptcy Rule 3017(c) provides that “[o]n or before approval of the 

disclosure statement, the court . . . may fix a date for the hearing on confirmation” of a plan of 

reorganization. Fed. R. Bankr. P. 3017(c). In addition, Bankruptcy Rule 2002(b) requires 28

Case 21-13797-SMG Doc 881 Filed 04/21/23 Page 5 of 26
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days’ notice of any hearing to consider approval of a disclosure statement or confirmation of a 

plan of reorganization. Courts have allowed combined hearings for approval of disclosure 

statements and the confirmation of reorganization and liquidation. See, e.g., In re Wynwood 

Community Economic Development Corporation, Inc., U.S. Bankruptcy Court, Southern District 

of Florida, Case No. 05−15867−BKC-AJC [ECF No. #464]; In re Mercedes Homes Inc., et al., 

U.S. Bankruptcy Court, Southern District of Florida, Case No. 09-11191-BKC-PJB [ECF No.

#958]; Aquatic Development Group, Inc. v. Thomas (In re Aquatic Development Group, Inc.), 

196 B.R. 666, 668 (N.D.N.Y. 1996); In re Machne Menachem, Inc., 304 B.R. 140, 142 (Bankr. 

M.D. Pa. 2003); In re Zenith Electric Corp., 241 B.R. 92, 96 (Bankr. D. Del. 1999); In re 

Pineloch Enters., Inc., 192 B.R. 675, 677 (Bankr. E.D.N.C. 1996).

16. As such, this Bankruptcy Court has the authority to conditionally approve the 

Disclosure Statement and consider final approval of the Disclosure Statement in conjunction 

with confirmation of the Plan.

17. Bankruptcy Code § 1125(b) requires that, prior to the plan solicitation, a plan 

proponent provide a disclosure statement that contains adequate information regarding the 

proposed plan. 11 U.S.C. § 1125(b)(1). Section 1125(a) defines “adequate information” as: 

[I]nformation of the kind, and in sufficient detail, as far as is reasonably 

practicable in light of the nature and history of the debtor and the condition of the 

debtor’s books and records, including a discussion of the potential material 

Federal tax consequences of the plan to the debtor, any successor to the debtor, 

and a hypothetical investor typical of the holders of claims or interests in the case, 

that would enable such a hypothetical investor of the relevant class to make an 

informed judgment about the plan, but adequate information need not include 

such information about any other possible or proposed plan and in determining 

whether a disclosure statement provides adequate information, the court shall 

consider the complexity of the case, the benefit of additional information to 

creditors and other parties in interest, and the cost of providing additional 

information . . . .

11 U.S.C. § 1125(a)(1).

Case 21-13797-SMG Doc 881 Filed 04/21/23 Page 6 of 26
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18. The amount and type of information required to satisfy Bankruptcy Code § 

1125(a) must be determined on a case-by-case basis. The legislative history of that statute 

supports the assertion that the threshold of what constitutes “adequate information” is f lexible 

and based on the circumstances of each case. See H.R. Rep. No. 95-595, 95th Cong., 1st Sess. at 

409 (1977).

19. Courts also have broad discretion to determine what constitutes adequate 

information necessary to satisfy the requirements of Bankruptcy Code § 1125(a). See In re 

Phoenix Petroleum Co., 278 B.R. 385, 393 (Bankr. E.D. Pa. 2001). This grant of discretion was

intended to facilitate a debtor’s effective emergence from Chapter 11 in the broad range of 

businesses in which Chapter 11 debtors engage. See H.R. Rep. No. 595, 95th Cong., 1st Sess. 408-

409 (1977). The general purpose of the disclosure statement is to set forth suf ficient f acts and 

information to permit a creditor to make an informed evaluation of the merits of the plan. See 

Century Glove, Inc. v. First American Bank of New York, 860 F.2d 94, 100 (3d Cir. 1988); In re 

Phoenix Petroleum Co., 278 B.R. 385 at 392.

20. To determine whether a disclosure statement contains adequate information, 

courts typically look to the following factors, where applicable to the circumstances of the case: 

(a) the events which led to the filing of a bankruptcy petition; (b) a description of the available 

assets and their value; (c) the anticipated future of the company; (d) the source of inf ormation 

stated in the disclosure statement; (e) a disclaimer; (f) the present condition of the debtor while in 

Chapter 11; (g) the scheduled claims; (h) the future management of the debtor; (k) the Chapter 

11 plan or a summary thereof; (i) the estimated administrative expenses, including attorneys’ and 

accountants’ fees; (j) the collectability of accounts receivable; (k) financial information and data 

relevant to the creditors’ decision to accept or reject the Chapter 11 plan; (l) information relevant 

Case 21-13797-SMG Doc 881 Filed 04/21/23 Page 7 of 26
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to the risks posed to creditors under the plan; (m) the actual or projected realizable value f rom 

recovery of preferential or otherwise voidable transfers; (n) litigation likely to arise in a 

nonbankruptcy context; (o) tax attributes of the debtor; and (p) the relationship of the debtor with 

affiliates. See Phoenix Petroleum Co., 278 B.R. at 393, n.6.

21. The Disclosure Statement contains adequate information, as required by 

Bankruptcy Code § 1125, so that the voting class will be able to make an informed decision in 

voting to accept or reject the Plan. The Debtors submit that the Disclosure Statement is 

comprehensive and contains the type of information described above. The Disclosure Statement 

includes complete discussions of: (a) the features, terms, and provisions of the Plan; (b) 

significant events preceding the Debtors’ Chapter 11 cases; (c) the Debtors’ pre-petition 

operations and businesses; (d) significant events in the Debtors’ Chapter 11 cases; (e) a detailed 

description of the funding of the Plan and making distributions to creditors; (g) a description of 

the nature and extent of likely claims against the Debtors’ estates; (h) the risk factors affecting 

the Plan; (i) an analysis setting forth the estimated return that creditors will receive under the 

Plan; and (j) the federal tax consequences of the Plan.

22. Based upon the foregoing, conditional approval of the Disclosure Statement is 

consistent with Bankruptcy Code § 1125, and such conditional approval, subject to final 

approval at the Combined Hearing, is in the best interests of the Debtors’ estates and the 

Debtors’ creditors.

B. Scheduling of Combined Hearing for Final Approval of Disclosure Statement

23. The Debtors respectfully request that the Court schedule a Combined Hearing to, 

among other things (as described more fully below with respect to confirmation of the Plan), 

consider final approval of the Disclosure Statement. The Combined Hearing may be continued 

Case 21-13797-SMG Doc 881 Filed 04/21/23 Page 8 of 26
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from time to time by the Bankruptcy Court or the Debtors without further notice other than 

adjournments announced in open court.

24. Bankruptcy Rule 3017(a) provides:

[A]fter a disclosure statement is filed in accordance with Rule 3016(b), the court 

shall hold a hearing on at least 28 days’ notice to the debtor, creditors, equity 

security holders and other parties in interest as provided in Rule 2002 to consider 

the disclosure statement and any objections or modifications thereto. The plan and 

the disclosure statement shall be mailed with the notice of the hearing only to the 

debtor, any trustee or committee appointed under the Code, the Securities and 

Exchange Commission, and any party in interest who requests in writing a copy 

of the statement or plan.

Fed. R. Bankr. P. 3017(a). Local Rule 3017-1 provides that objections to a disclosure statement 

must be made at least seven days prior to the hearing to approve such disclosure statement. The 

Debtors submit that good cause exists to modify these deadlines.

25. Bankruptcy Rules 2002(b) and (d) require notice by mail to all creditors, 

indenture trustees, and equity security holders of the time set for filing objections to, and the 

hearing to consider approval of, a disclosure statement. In order to satisfy these requirements, if 

and when the Court enters the Disclosure Statement Order, the Debtors will (i) mail a copy of the 

Disclosure Statement Order, the Plan and the Disclosure Statement to all parties entitled to vote 

on the Plan; (ii) mail a copy of the Disclosure Statement Order and the Non-Voting Notice to all 

holders of Claims and Equity Interests who are not eligible to vote because they are either 

presumed to have accepted or rejected the Plan pursuant to sections 1126(f) or (g) of the 

Bankruptcy Code, and (iii) mail a copy of the Disclosure Statement Order and the Confirmation 

Notice to all persons on the master mailing matrix and all other parties-in-interest that filed a 

request for notices under Bankruptcy Rule 2002 in these chapter 11 cases who are not holders of 

a Claim or Equity Interest.

26. In accordance with Bankruptcy Rule 3017(a), the Debtorswill include a copy of 

Case 21-13797-SMG Doc 881 Filed 04/21/23 Page 9 of 26
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the Disclosure Statement Order, the proposed Disclosure Statement, and the Plan, along with a 

notice of the Combined Hearing, to the Office of the United States Trustee, the Internal Revenue 

Service and the Securities and Exchange Commission. The Debtors will also provide copies of 

the proposed Disclosure Statement and the Plan to any party in-interest who specifically requests 

them in the manner specified in the Disclosure Statement Order and Bankruptcy Rule 3017(a). 

Copies of the proposed Disclosure Statement and the Plan are available free of charge at 

www.stretto.com/libertypower and will also remain on file with the Office of the Clerk of the 

Bankruptcy Court and viewable through access to the PACER and ECF systems at 

ecf.flsb.uscourts.gov (for a fee).

27. The Debtors further request that the Bankruptcy Court require that all objections 

to final approval of the Disclosure Statement: (a) be in writing; (b) comply with the Bankruptcy 

Code, the Bankruptcy Rules, and the local Bankruptcy Rules; (c) set forth the name of the 

objector, and the nature of the amount of any claim or equity security interest asserted by the 

objector against the estates or property of the Debtors; (d) state with particularity the legal and 

factual basis for such objection; and (e) be filed with the Clerk of the United States Bankruptcy 

Court for the Southern District of Florida, together with proof of service thereof, and served by

e-mail, personal service or overnight delivery, so as to be received no later than 5:00 p.m. 

prevailing Eastern Time, 7 calendar days before the Combined Hearing by: (i) counsel to 

the Debtors, Paul J. Battista, Esq., c/o Venable LLP, 100 SE 2nd St., 44th Floor, Miami, Florida 

33131 or at pjbattista@venable.com; (ii) counsel to BETM, Jordi Guso, Esq. c/o Berger 

Singerman at 1450 Brickell Ave, Unit 1900, Miami, Florida 33131 or at

jguso@bergersingerman.com; and (iii) the Office of the United States Trustee at 51 SW 1st

Avenue, Room 1202, Miami, Florida, 33130, c/o Martin P. Ochs, Esq., or at 

Case 21-13797-SMG Doc 881 Filed 04/21/23 Page 10 of 26
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martin.p.ochs@usdoj.gov. 

28. The Debtors respectfully submit that the foregoing procedures provide adequate 

notice for final approval of the Disclosure Statement at the Combined Hearing under the 

Bankruptcy Rules.

C. Scheduling of Combined Hearing as Evidentiary

29. Bankruptcy Rule 3017(c) provides:

On or before approval of the disclosure statement, the court shall fix a time within 

which the holders of claims and interests may accept or reject the plan and may 

fix a date for the hearing on confirmation.

Fed. R. Bankr. P. 3017(c).

30. The Debtors respectfully request that the Combined Hearing be an evidentiary 

hearing to consider confirmation of the Plan.

D. Voting Deadline for Receipt of Ballots and Ballot Tabulation

31. The deadline for filing ballots accepting or rejecting a chapter 11 plan is 14 

calendar days before the Combined Hearing (the “Voting Deadline”).

E. Transmittal of Solicitation Packages

32. No later than 30 days prior to the Combined Hearing, the Debtors will commence 

Solicitation by transmitting a solicitation package (the “Solicitation Package”) to holders of 

impaired claims and interests entitled to vote on the Plan. The Debtors submit that shortening 

the notice periods set forth in Bankruptcy Rule 3017(d) and Local Rule 3017-1(B)(2) is 

sufficient because the Class 4 Secured Claim of Boston Energy Trading and Marketing LLC (All 

Debtors) is the only impaired Class eligible to vote on the Plan. The Solicitation Package will 

consist of: (a) the conditionally-approved Disclosure Statement; (b) the Disclosure Statement 

Order; (c) the appropriate ballot; (d) the Plan; and (e) written notice of (i) the Bankruptcy Court’s 

conditional approval of the Disclosure Statement, (ii) the deadline and procedures for filing 

Case 21-13797-SMG Doc 881 Filed 04/21/23 Page 11 of 26
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objections to confirmation of the Plan, and (ii) related issues (the “Solicitation Notice”). In 

addition, the Debtors will transmit the Disclosure Statement Order, and Non-Voting Notice or 

the Confirmation Notice to the applicable parties. 

33. No interested party will be prejudiced by the proposed notice procedures. All of 

the Debtors’ impaired creditors entitled to vote will receive copies of the Disclosure Statement 

and the Plan. The Disclosure Statement and the Plan will be filed with the Court and can be 

obtained free of charge at www.stretto.com/libertypower or through this Court’s ECF 

notification e-mails. Additionally, the Disclosure Statement and Plan can be obtained by any 

interested party on written request the Debtors’ counsel at the following address: Venable LLP, 

100 SE 2nd Street Suite 4400, Miami, FL 33131, (305) 349-2300 Attn: Paul J. Battista, 

pjbattista@venable.com.

34. The foregoing notice procedures constitute adequate notice of the Combined 

Hearing to consider confirmation of the Plan and the Confirmation Objection Deadline. 

Consequently, the Debtors respectfully request that the Bankruptcy Court approve the manner of 

service of the proposed notices. 

CONCLUSION

35. For the above reasons, the Debtors respectfully request that the Bankruptcy Court: 

(i) enter the Disclosure Statement Order granting the relief requested in this Motion; (ii) approve 

the form of the Notice of Non-Voting Status and solicitation procedures in connection therewith 

in the form attached as Exhibit A; (iii) approve the form of the Confirmation Notice and 

solicitation procedures in connection therewith in the form attached as Exhibit B; and (iv) and 

grant such other relief as the Bankruptcy Court deems appropriate.

Dated: April 21, 2023

Case 21-13797-SMG Doc 881 Filed 04/21/23 Page 12 of 26
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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/ Paul J. Battista 

 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 881 Filed 04/21/23 Page 13 of 26
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EXHIBIT A 

Form of Notice of Non-Voting Status

Case 21-13797-SMG Doc 881 Filed 04/21/23 Page 14 of 26
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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 COLUMBIA, LLC Case No. 21-15540-SMG

Debtors. (Jointly administered 21-13797-SMG) 

/ 

NOTICE OF NON-VOTING STATUS 

PLEASE TAKE NOTICE THAT LIBERTY POWER HOLDINGS, LLC, LPT, 

LLC, LIBERTY POWER MARYLAND, LLC and LIBERTY POWER DISTRICT OF 

COLUMBIA, LLC (collectively, the “Debtors”), commenced a case under chapter 11 of title 11

of the United States Code (the “Bankruptcy Code”) in the United StatesBankruptcy Court for the

Southern Districtof Florida (the “Bankruptcy Court”).

PLEASE TAKE FURTHER NOTICE THAT on April ___, 2023, the Bankruptcy 

Court entered an order [ECF No. ____] (the “Disclosure Statement Order”): (a) authorizing the 

Debtors to solicit votes on the Joint Chapter 11 Plan of Liquidation Proposed By Liberty Power 

Holdings, LLC, LPT, LLC, Liberty Power Maryland, LLC and Liberty Power District of 

Columbia, LLC [ECF No. 875] (as may be amended,supplemented,or otherwise modified from 

time to time, the “Plan”); (b) conditionally approving the Joint Disclosure Statement For Joint 

Chapter 11 Plan of Liquidation Proposed By Liberty Power Holdings, LLC, LPT, LLC, Liberty 

Power Maryland, LLC and Liberty Power District of Columbia, LLC [ECF No. _____] (as may 

be amended, supplemented, or otherwise modified from time to time, the “Disclosure Statement”)

as containing “adequate information” pursuant to section 1125 of the Bankruptcy Code; (c) 

authorizing solicitation of votes on the Plan; (d) approving solicitation procedures for voting on 

the Plan; (e) approving additional notice procedures for non-voting parties (f) scheduling a 

combined hearing for final approval of the Disclosure Statement and hearing on confirmation of 

the Plan (the “Combined Hearing”); and (g) scheduling certain dates with respect thereto.

PLEASE TAKE FURTHER NOTICE THAT because of the nature and treatment of 

your Claim or Equity Interest under the Plan, you are not entitled to vote on the Plan. 

Specifically, under the terms of the Plan, as a Holder of a Claim (as currently asserted against the 

Debtors) that is either: (1) Unimpaired and conclusively presumed to accept the Plan pursuant to 

section 1126(f) of the Bankruptcy Code; or (2) Impaired and conclusively presumed to reject the

Plan pursuant to section 1126(g) of the Bankruptcy Code because you will not receive a 

Distribution or retain any property under the Plan on account of your Claim or Equity Interest, 

Case 21-13797-SMG Doc 881 Filed 04/21/23 Page 15 of 26
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PLEASE BE ADVISED: THE COMBINED HEARING MAY BE CONTINUED FROM 

TIME TO TIME BY THE COURT OR THE DEBTORS WITHOUT FURTHER 

NOTICE OTHER THAN BY SUCH ADJOURNMENT BEING ANNOUNCED IN

OPEN COURT OR BY A NOTICE OF ADJOURNMENT FILED WITH THE COURT 

AND SERVED ON PARTIES ENTITLED TO NOTICE.

you are not entitled to vote on the Plan.

PLEASE TAKE FURTHER NOTICE THAT the Combined Hearing to consider f inal 

approval of the Disclosure Statement and confirmation of the Plan will commence on 

__________, 2023, at _________, prevailing Eastern Time, before the Honorable Scott M. 

Grossman, in the United States Bankruptcy Court for the Southern District of Florida – Fort 

Lauderdale Division, located at 299 E. Broward Blvd., Courtroom 308, Fort Lauderdale, Florida 

33301

PLEASE TAKE FURTHER NOTICE THAT you may participate in the Combined 

Hearing either in person or by an audio and video connection. Although the Court will conduct 

the Combined Hearing in person, any interested party may choose to attend the hearing remotely 

using the services of Zoom Video Communications, Inc. ("Zoom"), which permits remote 

participation by video or by telephone, if the judge's procedures allow. To participate in the 

hearing remotely via Zoom (whether by video or by telephone), you must register in advance no 

later than 3:00 p.m., one business day before the date of the Combined. To register, click on or 

manually enter the following registration link in a browser:

https://www.zoomgov.com/meeting/register/vJIsceqsqzMtG7hezfpqRtlAFR1SzvHOb

JU

All participants (whether attending in person or remotely) must observe the formalities of 

the courtroom, exercise civility, and otherwise conduct themselves in a manner consistent with 

the dignity of the Court. This includes appropriate courtroom attire for those participants 

appearing in person or by video

PLEASE TAKE FURTHER NOTICE THAT the deadline for filing objections to 

the adequacy of the Disclosure Statement or confirmation of the Plan is ____________, 2023 

(the “Objection Deadline”). Any objections to the relief sought at the Combined Hearing

must be: (i) in writing; (ii) comply with the Bankruptcy Code, Bankruptcy Rules, and

Local Rules; (iii) state, with specificity, the legal and factual bases thereof, and, if 

practicable, a proposed modification to the Disclosure Statement or Plan (or related materials) 

that would resolve such objection; and (iv) be filed with the Court on or before the Objection 

Deadline.

PLEASE TAKE FURTHER NOTICE THAT, if you wish to challenge the Debtors’ 

classification of yourClaim, you mustfile a motion,pursuanttoBankruptcyRule 3018(a) (a “Rule

3018 Motion”), for an order temporarily allowing your Claim in a different classification or 

Case 21-13797-SMG Doc 881 Filed 04/21/23 Page 16 of 26
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amount for purposes of voting to accept or reject the Plan and file such motion on or before

_________,2023. In accordancewithBankruptcyRule 3018, asto any creditorfiling a Rule 3018

Motion, such creditor’s ballot will not be counted unless temporarily allowed by the Bankruptcy

Court for votingpurposes,after notice and a hearing. Rule 3018 Motionsthat are nottimely filed

and served in the manner set forth above will not be considered.

PLEASE TAKE FURTHER NOTICE THAT if you have any questions about the

materials you have received, please contact Stretto, the Debtors’ claims and noticing agent (the 

“Noticing Agent”), at 855.529.1663 (domestic toll free) or +1 949.771.2210 (International). 

Copies of the Disclosure Statement, the Plan, and any other publicly filed documents in the 

Chapter 11 Cases are available upon written request to the Noticing Agent at the following 

address:

By Regular, Hand Delivery, or Overnight Mail:

Liberty Power Holdings, LLC

BallotProcessing 

c/o Stretto

410 Exchange, Suite 100

Irvine, California 9260

By Email:

libertypowerinquiries@stretto.com

PLEASE TAKE FURTHER NOTICE THAT copies of the Plan, the Disclosure 

Statement, and any other publicly filed documents are also available by downloading the exhibits 

and documents from the website of the Debtors’ Voting Agent at

https://cases.stretto.com/LibertyPower (free of charge) or the Court’s website at

https://ecf.flsb.uscourts.gov (for a fee). Please be advised that Stretto cannot provide legal or 

financial advice.

ARTICLE XI OF THE PLAN CONTAINS INJUNCTION AND EXCULPATION 

PROVISIONS. YOU ARE ADVISED TO REVIEW AND CONSIDER THE PLAN 

CAREFULLY BECAUSE YOUR RIGHTS MIGHT BE AFFECTED THEREUNDER. 

THIS NOTICE IS BEING SENT TO YOU FOR INFORMATIONAL PURPOSES ONLY.

PLAN INJUNCTION

Except as otherwise expressly provided for in the Plan or in obligations issued 

pursuant to the Plan, all Persons and Entities are permanently enjoined, on and after the 

Effective Date, on account of any Claim or Equity Interest, from: (i) commencing or 

continuing in any manner any action or other proceeding of any kind against the Debtors, 

their Estates and their successors and assigns and its assets and properties; (ii) enforcing, 

determining, attaching, collecting or recovering by any manner or means any liability, 

claim, judgment, award, decree or order against the Debtors and their Estates, and their 

successors and assigns and their assets and properties; (iii) creating, perfecting or 

enforcing any encumbrance of any kind against the Debtors, and their Estates and their 

successors and assigns and their assets and properties; and (iv) commencing or continuing 

in any manner any action or other proceeding of any kind in respect of any Claim or 

Case 21-13797-SMG Doc 881 Filed 04/21/23 Page 17 of 26
18

Equity Interest or Cause of Action released or settled hereunder, provided however, that 

nothing in the Plan or Confirmation Order shall constitute a waiver of any rights or 

defenses of such persons with respect to such actions, provided, further, that such 

injunction shall neither bar any entity from asserting any defense in an action commenced 

by or on behalf of the Debtors, nor prohibit any entity from asserting any right expressly 

preserved or contemplated by the Plan; provided, furthermore, that nothing contained in 

the Plan or Confirmation Order shall preclude the IRS from pursuing an action against 

any entity, or preclude any governmental entity from pursuing a criminal, police or 

regulatory action against any entity. Nothing herein shall be construed as enjoining any 

party’s prosecution or defense of any appeal of any order entered by the Bankruptcy Court 

in these Chapter 11 Cases.

EXCULPATION

Notwithstanding anything in the Plan to the contrary, the Exculpated Parties shall 

neither have nor incur any liability to any Person or Entity for any and all Claims and 

Causes of Action arising on or after the Petition Date up through the time these Chapter 11 

Cases are closed, involving or relating to any act taken or omitted to be taken in connection 

with, or related to, prosecuting these Chapter 11 Cases, formulating, negotiating, 

preparing, disseminating, implementing, or administering any aspect of these Chapter 11 

Cases, including the sale of property of the Estate, distributing property of the Estate or 

related in any way to any other contract, instrument, release or other agreement or 

document created or entered into in connection with these Chapter 11 Cases, the Plan or 

any other post-petition act taken or omitted to be taken in connection with or in 

contemplation of the administration of the Estate; provided, however, that the foregoing 

provisions of this paragraph shall have no effect on the liability of any person that results 

from any such act or omission that is determined to have constituted gross negligence, 

willful misconduct, or fraud; provided further, that nothing contained in the Confirmation 

Order shall preclude any governmental entity from pursuing a criminal, police or 

regulatory action against any entity.

Nothing in the Plan shall be construed to release or exculpate any Person from, or 

require indemnification of, any Person against losses arising from criminal conduct, 

intentional unauthorized misuse of confidential information that causes damages, or limit 

the liability of the professionals of the Debtors to the Debtors pursuant to Rule 4-1.8(h) of 

the Florida Rules of Professional Conduct (“Limiting Liability for Malpractice”). 

“Exculpated Parties” shall mean (a) each of Stephen Gray, Jay Goldman and Louis 

Martinsen as certain of the Debtors’ respective present and former managers, (b) Bob 

Butler as the Debtors’ chief restructuring officer, (c) Michael Brown, as the Debtor’s chief 

financial officer, (d) each of the Debtors’ employees who were employed by the Debtors 

from and after the Petition Date; (e) all Professionals (including ordinary course 

professionals) whose employment has been approved by the Bankruptcy Court in the 

Chapter 11 Cases, including Genovese Joblove & Battista, P.A., Venable LLP and Berkeley 

Research Group, LLC, and each of their respective attorneys, paraprofessionals and 

employees, and (f) BETM and all its managers, members, professionals and 

representatives, including Berger Singerman LLP and Eversheds Sutherland, and each of 

Case 21-13797-SMG Doc 881 Filed 04/21/23 Page 18 of 26
19

their respective attorneys, paraprofessionals and employees.

[Remainder of Page Intentionally Left Blank]

Case 21-13797-SMG Doc 881 Filed 04/21/23 Page 19 of 26
20

Dated:______________, 2023

 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/ Paul J. Battista 

 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 881 Filed 04/21/23 Page 20 of 26
21

EXHIBIT B 

Form of Confirmation Notice

Case 21-13797-SMG Doc 881 Filed 04/21/23 Page 21 of 26
22

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 COLUMBIA, LLC Case No. 21-15540-SMG

Debtors. (Jointly administered 21-13797-SMG) 

/ 

NOTICE OF CONFIRMATION HEARING

PLEASE TAKE NOTICE THAT LIBERTY POWER HOLDINGS, LLC, LPT, 

LLC, LIBERTY POWER MARYLAND, LLC and LIBERTY POWER DISTRICT OF 

COLUMBIA, LLC (collectively, the “Debtors”), commenced a case under chapter 11 of title 11

of the United States Code (the “Bankruptcy Code”) in the United StatesBankruptcy Court for the

Southern Districtof Florida (the “Bankruptcy Court”).

PLEASE TAKE FURTHER NOTICE THAT on April ___, 2023, the Bankruptcy 

Court entered an order [ECF No. ____] (the “Disclosure Statement Order”): (a) authorizing the 

Debtors to solicit votes on the Joint Chapter 11 Plan of Liquidation Proposed By Liberty Power 

Holdings, LLC, LPT, LLC, Liberty Power Maryland, LLC and Liberty Power District of 

Columbia, LLC [ECF No. 875] (as may be amended,supplemented,or otherwise modified from 

time to time, the “Plan”); (b) conditionally approving the Joint Disclosure Statement For Joint 

Chapter 11 Plan of Liquidation Proposed By Liberty Power Holdings, LLC, LPT, LLC, Liberty 

Power Maryland, LLC and Liberty Power District of Columbia, LLC [ECF No. _____] (as may 

be amended, supplemented, or otherwise modified from time to time, the “Disclosure Statement”)

as containing “adequate information” pursuant to section 1125 of the Bankruptcy Code; (c) 

authorizing solicitation of votes on the Plan; (d) approving solicitation procedures for voting on 

the Plan; (e) approving additional notice procedures for non-voting parties; (f) scheduling a 

combined hearing for final approval of the Disclosure Statement and hearing on confirmation of 

the Plan (the “Combined Hearing”); and (g) scheduling certain dates with respect thereto.

PLEASE TAKE FURTHER NOTICE THAT because you are not a holder of a Claim 

or Equity Interest under the Plan, you are not entitled to vote on the Plan. 

PLEASE TAKE FURTHER NOTICE THAT the Combined Hearing to consider f inal 

approval of the Disclosure Statement and confirmation of the Plan will commence on 

__________, 2023, at _________, prevailing Eastern Time, before the Honorable Scott M. 

Grossman, in the United States Bankruptcy Court for the Southern District of Florida – Fort 

Lauderdale Division, located at 299 E. Broward Blvd., Courtroom 308, Fort Lauderdale, Florida 

Case 21-13797-SMG Doc 881 Filed 04/21/23 Page 22 of 26
23

PLEASE BE ADVISED: THE COMBINED HEARING MAY BE CONTINUED FROM 

TIME TO TIME BY THE COURT OR THE DEBTORS WITHOUT FURTHER 

NOTICE OTHER THAN BY SUCH ADJOURNMENT BEING ANNOUNCED IN

OPEN COURT OR BY A NOTICE OF ADJOURNMENT FILED WITH THE COURT 

AND SERVED ON PARTIES ENTITLED TO NOTICE.

33301.

PLEASE TAKE FURTHER NOTICE THAT you may participate in the Combined 

Hearing either in person or by an audio and video connection. Although the Court will conduct 

the Combined Hearing in person, any interested party may choose to attend the hearing remotely 

using the services of Zoom Video Communications, Inc. ("Zoom"), which permits remote 

participation by video or by telephone, if the judge's procedures allow. To participate in the 

hearing remotely via Zoom (whether by video or by telephone), you must register in advance no 

later than 3:00 p.m., one business day before the date of the Combined. To register, click on or 

manually enter the following registration link in a browser:

https://www.zoomgov.com/meeting/register/vJIsceqsqzMtG7hezfpqRtlAFR1SzvHObJU

All participants (whether attending in person or remotely) must observe the formalities of 

the courtroom, exercise civility, and otherwise conduct themselves in a manner consistent with 

the dignity of the Court. This includes appropriate courtroom attire for those participants 

appearing in person or by video

PLEASE TAKE FURTHER NOTICE THAT the deadline for filing objections to the 

adequacy of the Disclosure Statement or confirmation of the Plan is ____________, 2023 (the 

“Objection Deadline”). Any objections to the relief sought at the Combined Hearing must be: 

(i) in writing; (ii) comply with the Bankruptcy Code, Bankruptcy Rules, and Local Rules; 

(iii) state, with specificity, the legal and factual bases thereof, and, if practicable, a proposed 

modification to the Disclosure Statement or Plan (or related materials) that would resolve such 

objection; and (iv) be filed with the Court on or before the Objection Deadline.

PLEASE TAKE FURTHER NOTICE THAT, if you wish to challenge the Debtors’ 

classification of yourClaim, you mustfile a motion,pursuanttoBankruptcyRule 3018(a) (a “Rule

3018 Motion”), for an order temporarily allowing your Claim in a different classification or 

amount for purposes of voting to accept or reject the Plan and file such motion on or before

_________,2023. In accordancewithBankruptcyRule 3018, asto any creditorfiling a Rule 3018

Motion, such creditor’s ballot will not be counted unless temporarily allowed by the Bankruptcy

Court for votingpurposes,after notice and a hearing. Rule 3018 Motionsthat are nottimely filed

and served in the manner set forth above will not be considered.

PLEASE TAKE FURTHER NOTICE THAT if you have any questions about the

materials you have received, please contact Stretto, the Debtors’ claims and noticing agent (the 

“Noticing Agent”, at 855.529.1663 (domestic toll free) or +1 949.771.2210 (International). 

Copies of the Disclosure Statement, the Plan, and any other publicly filed documents in the 

Case 21-13797-SMG Doc 881 Filed 04/21/23 Page 23 of 26
24

Chapter 11 Cases are available upon written request to the Noticing Agent at the following 

address:

By Regular, Hand Delivery, or Overnight Mail:

Liberty Power Holdings, LLC

BallotProcessing 

c/o Stretto

410 Exchange, Suite 100

Irvine, California 9260

By Email:

libertypowerinquiries@stretto.com

PLEASE TAKE FURTHER NOTICE THAT copies of the Plan, the Disclosure 

Statement, and any other publicly filed documents are also available by downloading the exhibits 

and documents from the website of the Debtors’ Voting Agent at

https://cases.stretto.com/LibertyPower (free of charge) or the Court’s website at

https://ecf.flsb.uscourts.gov (for a fee). Please be advised that Stretto cannot provide legal or 

financial advice.

ARTICLE XI OF THE PLAN CONTAINS INJUNCTION AND EXCULPATION 

PROVISIONS. YOU ARE ADVISED TO REVIEW AND CONSIDER THE PLAN 

CAREFULLY BECAUSE YOUR RIGHTS MIGHT BE AFFECTED THEREUNDER. THIS 

NOTICE IS BEING SENT TO YOU FOR INFORMATIONAL PURPOSES ONLY.

PLAN INJUNCTION

Except as otherwise expressly provided for in the Plan or in obligations issued pursuant 

to the Plan, all Persons and Entities are permanently enjoined, on and after the Effective Date, 

on account of any Claim or Equity Interest, from: (i) commencing or continuing in any manner 

any action or other proceeding of any kind against the Debtors, their Estates and their 

successors and assigns and its assets and properties; (ii) enforcing, determining, attaching, 

collecting or recovering by any manner or means any liability, claim, judgment, award, decree 

or order against the Debtors and their Estates, and their successors and assigns and their assets 

and properties; (iii) creating, perfecting or enforcing any encumbrance of any kind against the 

Debtors, and their Estates and their successors and assigns and their assets and properties; and 

(iv) commencing or continuing in any manner any action or other proceeding of any kind in 

respect of any Claim or Equity Interest or Cause of Action released or settled hereunder, 

provided however, that nothing in the Plan or Confirmation Order shall constitute a waiver of 

any rights or defenses of such persons with respect to such actions, provided, further, that such 

injunction shall neither bar any entity from asserting any defense in an action commenced by 

or on behalf of the Debtors, nor prohibit any entity from asserting any right expressly 

preserved or contemplated by the Plan; provided, furthermore, that nothing contained in the 

Plan or Confirmation Order shall preclude the IRS from pursuing an action against any entity, 

or preclude any governmental entity from pursuing a criminal, police or regulatory action 

against any entity. Nothing herein shall be construed as enjoining any party’s prosecution or 

defense of any appeal of any order entered by the Bankruptcy Court in these Chapter 11 Cases.

Case 21-13797-SMG Doc 881 Filed 04/21/23 Page 24 of 26
25

EXCULPATION

Notwithstanding anything in the Plan to the contrary, the Exculpated Parties shall 

neither have nor incur any liability to any Person or Entity for any and all Claims and Causes 

of Action arising on or after the Petition Date up through the time these Chapter 11 Cases are 

closed, involving or relating to any act taken or omitted to be taken in connection with, or 

related to, prosecuting these Chapter 11 Cases, formulating, negotiating, preparing, 

disseminating, implementing, or administering any aspect of these Chapter 11 Cases, including 

the sale of property of the Estate, distributing property of the Estate or related in any way to 

any other contract, instrument, release or other agreement or document created or entered into 

in connection with these Chapter 11 Cases, the Plan or any other post-petition act taken or 

omitted to be taken in connection with or in contemplation of the administration of the Estate; 

provided, however, that the foregoing provisions of this paragraph shall have no effect on the 

liability of any person that results from any such act or omission that is determined to have 

constituted gross negligence, willful misconduct, or fraud; provided further, that nothing 

contained in the Confirmation Order shall preclude any governmental entity from pursuing a 

criminal, police or regulatory action against any entity.

Nothing in the Plan shall be construed to release or exculpate any Person from, or 

require indemnification of, any Person against losses arising from criminal conduct, intentional 

unauthorized misuse of confidential information that causes damages, or limit the liability of 

the professionals of the Debtors to the Debtors pursuant to Rule 4-1.8(h) of the Florida Rules of 

Professional Conduct (“Limiting Liability for Malpractice”). 

“Exculpated Parties” shall mean (a) each of Stephen Gray, Jay Goldman and Louis 

Martinsen as certain of the Debtors’ respective present and former managers, (b) Bob Butler as 

the Debtors’ chief restructuring officer, (c) Michael Brown, as the Debtor’s chief financial 

officer, (d) each of the Debtors’ employees who were employed by the Debtors from and after 

the Petition Date; (e) all Professionals (including ordinary course professionals) whose 

employment has been approved by the Bankruptcy Court in the Chapter 11 Cases, including 

Genovese Joblove & Battista, P.A., Venable LLP and Berkeley Research Group, LLC, and each 

of their respective attorneys, paraprofessionals and employees, and (f) BETM and all its 

managers, members, professionals and representatives, including Berger Singerman LLP and 

Eversheds Sutherland, and each of their respective attorneys, paraprofessionals and employees.

[Remainder of Page Intentionally Left Blank]

Case 21-13797-SMG Doc 881 Filed 04/21/23 Page 25 of 26
Dated:_______________, 2023

 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/ Paul J. Battista 

 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 881 Filed 04/21/23 Page 26 of 26