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 Case No. 21-15540-SMG 

COLUMBIA, LLC, 

 (Jointly administered 21-13797-SMG) 

/ 

OBJECTION TO CLAIM OF 

THE OFFICE OF THE ILLINOIS ATTORNEY GENERAL 

(Proof of Claim No 99) 

IMPORTANT NOTICE TO CLAIMANT:

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 to: 

United States Bankruptcy Court 

United States Courthouse 

299 E. Broward Blvd., Room 112 

Ft. Lauderdale, FL 33301 

A copy of the written response must also be sent to: 

Case 21-13797-SMG Doc 781 Filed 09/06/22 Page 1 of 3
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Paul J. Battista, Esq. 

Mariaelena Gayo-Guitian,Esq. 

Genovese Joblove & Battista, P.A. 

100 Southeast Second Street, 44th Floor 

Miami, Florida 33131 

pbattista@gjb-law.com

mguitian@gjb-law.com

LIBERTY POWER HOLDINGS, LLC (“Holdings” or “Debtor”), one of the four abovecaptioned debtors in these chapter 11 cases, by and through its undersigned counsel, and pursuant 

to Fed. R. Bankr. P. 3007 and Local Rule 3007-1, files this objection (“Objection”) to Proof of 

Claim No. 99 filed by the Office of the Illinois Attorney General (“Illinois AG”) asserting an 

unsecured claim against Holdings in the amount of $154,382,184.00. In support of the Objection 

the Debtor states as follows: 

1. On October 13, 2021, the Illinois AG filed Proof of Claim No. 99 asserting an 

unsecured claim against Holdings in the amount of $154,382,184.00 (the “Illinois Claim”). The 

Illinois Claim is based on the alleged violations of the Illinois Consumer Fraud and Deceptive 

Business Practices Act (“Consumer Fraud Act”), 815 ILCS §505/1 et seq., and the Illinois 

Telephone Solicitations Act, 815 ILCS §413/1 et seq. (“Telephone Solicitations Act”) asserted in 

that certain action styled People of the State of Illinois v. Liberty Power Holdings, in the Circuit 

Court of Cook County, Illinois County Department, Chancery Division (Case No. 2020-CH 1954) 

(“Illinois State Court Action”). 

2. The Debtor objects to the Illinois Claim and the priority of the alleged civil penalty 

claim included therein. 

3. Based on the above, the Illinois Claim should be allowed as a general unsecured 

claim against Holdings in the amount of $77,191,092.00 (“Unsecured Claim”) and a subordinated 

general unsecured claim in the amount of $77,191,092.00 (“Subordinated Unsecured Claim”). 

Case 21-13797-SMG Doc 781 Filed 09/06/22 Page 2 of 3
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WHEREFORE, the Debtor respectfully requests that this Court enter an Order (i) 

sustaining the Objection; (ii) reclassifying and allowing the Illinois Claim as an allowed general 

Unsecured Claim against Holdings in the amount of $77,191,092.00 and a Subordinated 

Unsecured Claim in the amount of $77,191,092.00. 

 Dated this 6th day of September, 2022. 

 

 Respectfully Submitted, 

 GENOVESE JOBLOVE & BATTISTA, P.A. 

 Attorneys for Debtor-in-Possession 

100 Southeast Second Street, Suite 4400 

 Miami, Florida 33131 

 Telephone: (305) 349-2300 

 Facsimile: (305) 349-2310 

 By: /s/ Mariaelena Gayo-Guitian 

 Paul J. Battista, Esq. 

Florida Bar No. 884162 

pbattista@gjb-law.com 

Mariaelena Gayo-Guitian, Esq. 

Florida Bar No. 813818 

mguitian@gjb-law.com

Heather L. Harmon 

Florida Bar No. 13192 

hharmon@gjb-law.com

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