10321310-2 

UNITED STATES BANKRUPTCY COURT 

SOUTHERN DISTRICT OF FLORIDA 

FORT LAUDERDALE DIVISION 

www.flsb.uscourts.gov

In re: Chapter 11 

LIBERTY POWER HOLDINGS, LLC, Case No. 21-13797-PDR 

 Debtor. 

_______________________________________/ 

NOTICE OF APPEARANCE AND 

REQUEST FOR SERVICE OF PLEADINGS AND OTHER PAPERS 

TO ALL PARTIES, PLEASE TAKE NOTICE THAT: 

Berger Singerman LLP, as counsel for Creditor, Boston Energy Trading and Marketing, 

LLC (“Creditor”), hereby files this Notice of Appearance and Request for Service of Pleadings 

and Other Papers (the “Notice”), pursuant to section 1109(b) of title 11 of the United States 

Code, 11 U.S.C. §§ 101 et seq. (the “Bankruptcy Code”) and Rule 9010(b) of the Federal Rules 

of Bankruptcy Procedure (the “Bankruptcy Rules”), and that such party in interest hereby 

respectfully requests, pursuant to section 1109(b) of the Bankruptcy Code and Bankruptcy Rules 

2002, 9007 and 9010, that copies of all notices and pleadings given or requested to be served in 

this case be served upon the undersigned attorney at the following address: 

Jordi Guso, Esq. 

Berger Singerman LLP 

1450 Brickell Avenue, Suite 1900 

Miami, FL 33131 

Telephone: (305) 755-9500 

Facsimile: (305) 714-4340 

E-mail: jguso@bergersingerman.com

PLEASE TAKE FURTHER NOTICE that, pursuant section 1109(b) of the Bankruptcy 

Code and Rule 2002 of the Bankruptcy Rules, this request includes not only the notices and 

papers referred to in the Bankruptcy Rules specified above but also includes, without limitation, 

Case 21-13797-PDR Doc 16 Filed 04/22/21 Page 1 of 3
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any notice, application, motion, petition, complaint, demand, hearing, pleading, request, 

disclosure statement or plan of reorganization, whether formal or informal, written or oral, and 

whether transmitted or conveyed by mail, delivery, telephone, telegraph, telex, facsimile 

transmission, email, Internet or otherwise filed or given with regard to 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 with respect thereto. 

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 right of the 

Creditor (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 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 22, 2021 BERGER SINGERMAN LLP 

Counsel for Creditor

1450 Brickell Avenue, Suite 1900 

Miami, FL 33131 

Telephone: (305) 755-9500 

Facsimile: (305) 714-4340 

By: Jordi Guso 

Jordi Guso 

Florida Bar No. 863580 

jguso@bergersingerman.com

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CERTIFICATE OF SERVICE 

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

22nd day of April, 2021, by electronic transmission through the Court’s CM/ECF system upon 

all parties listed below on the CM/ECF Service List. 

By: Jordi Guso 

Jordi Guso 

CM/ECF Service List 

• Scott Andron sandron@broward.org, swulfekuhle@broward.org 

• Paul J. Battista pbattista@gjb-law.com, gjbecf@gjb-law.com;chopkins@gjblaw.com;jzamora@gjb-law.com;gjbecf@ecf.courtdrive.com;vlambdin@gjb-law.com 

• Heather L Harmon HHarmon@gjb-law.com, gjbecf@gjb-law.com;ecastellanos@gjblaw.com;gjbecf@ecf.courtdrive.com;jzamora@gjb-law.com 

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

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