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UNITED STATES BANKRUPTCY COURT 

SOUTHERN DISTRICT OF FLORIDA 

FORT LAUDERDALE DIVISION 

www.flsb.uscourts.gov 

In re: 

LIBERTY POWER HOLDINGS, LLC, et 

al.,

 Debtors. 

____________________________________/

Chapter 11 Cases 

Case No.: 21-13797-SMG

 (Jointly Administered) 

PHILIP J. VON KAHLE AS ASSIGNEE OF 

LIBERTY POWER CORPORATION’S EX PARTE MOTION 

TO ALLOW ATTORNEY DANA QUICK TO APPEAR BY ZOOM AT 

THE HEARING CURRENTLY SCHEDULED FOR MAY 24, 2023 

Philip J. von Kahle, in his capacity as the Assignee (the “Assignee”) for the benefit of 

creditors of Liberty Power Corporation (“LPC”), by and through undersigned counsel, hereby files 

this Ex Parte Motion to Allow Attorney Dana Quick to Appear by Zoom at the Hearing Currently 

Scheduled for May 24, 2023 (the “Motion”), to permit Dana Quick to appear remotely via Zoom 

at the hearing currently scheduled for May 24, 2023 at 1:30 p.m. (Prevailing Eastern Time) (as 

may be adjourned or continued, the “Hearing”). In support of the Motion, the Assignee 

respectfully represents as follows: 

I. BACKGROUND

1. On April 20, 2021 (the “Petition Date”), Liberty Power Holdings, LLC (the

“Debtor”) filed a voluntary petition for relief pursuant to Chapter 11 of Title 11 of the U.S. Code 

commencing the instant bankruptcy case. 

2. On May 14, 2021, LPC executed an assignment of substantially all of its assets to

the Assignee for the benefit of creditors, pursuant to Florida Statute, Chapter 727. On May 19, 

2021, the Assignee commenced the case styled In re the Assignment for the Benefit of Creditors 

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of Liberty Power Corp., LLC, Case No. CACE-21-010056, pending in the Seventeenth Judicial 

Circuit, in and for Broward County, Florida (the “Assignment Case”). 

3. On April 10, 2023, the Debtor filed Debtor’s Motion Pursuant to Section 105(a) of 

the Bankruptcy Code and Fed. R. Bankr. P. 9019 for Entry of an Order Approving the Terms of a 

Settlement By and Between the Debtors and the D&O Parties (ECF No. 871) (the “D&O Motion”) 

and Debtor’s Motion Pursuant to Section 105(a) of the Bankruptcy Code and Fed. R. Bankr. P. 

9019 for Entry of an Order Approving the Terms of a Settlement By and Among the Debtors, 

Boston Energy Trading and Marketing, LLC, and Peter S. Kaufman (ECF No. 872) (the “Kaufman 

Motion,” and together with the D&O Motion, the “Motions”). 

4. On April 24, 2023, the Court issued its Notice of Hearing (ECF No. 882), setting 

the Hearing on the Motion for May 24, 2023, at 1:30 p.m. 

5. The Assignee intends to file an objection to the Motion and will do so timely under 

the Local Rules. 

6. Pursuant to the Court’s Requirements and Procedures for Remote Attendance at 

Hearings Before Judge Grossman, the Assignee now filing a motion to permit Ms. Quick to appear 

via Zoom at that Hearing. 

II. REQUESTED RELIEF AND BASIS THEREFOR 

7. Pursuant to Section I(d) of Your Honor’s Requirements and Procedures for Remote 

Attendance at Hearings, an ex parte motion requesting leave to attend remotely for good cause 

must be filed not later than seven days before the hearing unless there are unforeseen 

circumstances. 

8. The Assignee submits that this Motion is being filed no later than seven days before 

the Hearing and good cause exists to grant the Motion. Ms. Quick resides outside of the State of 

Florida and will be outside of the State of Florida on the day of the Hearing. Accordingly, the 

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Assignee moves, on an ex parte basis, for entry of an Order substantially in the form annexed 

hereto as Exhibit A authorizing Ms. Quick to appear at the Hearing via Zoom. 

WHEREFORE, the Assignee respectfully requests entry of an Order in the form annexed 

hereto as Exhibit A (i) authorizing Ms. Quick to appear remotely via Zoom and (ii) granting such 

other and further relief as is just and proper. 

Dated: May 17, 2023 

Respectfully submitted, 

BAST AMRON LLP 

Counsel for Assignee, Philip J. von Kahle for the 

Benefit of Creditors of Liberty Power Corp., LLC 

One Southeast Third Ave., Suite 2410 

Miami, Florida 33131 

Telephone: 305.379.7904 

Facsimile: 786.206.8740 

Email: jbast@bastamron.com 

Email: dquick@bastamron.com

By: /s/ Dana R. Quick 

Jeffrey P. Bast (FBN 996343) 

Dana R. Quick (FBN 074402) 

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CERTIFICATE OF SERVICE 

I hereby certify that on this 17th day of May, 2023, true and correct copies of the foregoing 

were served electronically via the Court’s electronic filing system on all parties registered to 

receive notifications via CM/ECF in this case. 

 /s/ Dana R. Quick 

 Dana R. Quick, Esq. 

 

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EXHIBIT A 

 

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[PROPOSED ORDER] 

UNITED STATES BANKRUPTCY COURT 

SOUTHERN DISTRICT OF FLORIDA 

FORT LAUDERDALE DIVISION 

www.flsb.uscourts.gov 

In re: 

LIBERTY POWER HOLDINGS, LLC, et 

al.,

 Debtors. 

____________________________________/

Chapter 11 Cases 

Case No.: 21-13797-SMG

 (Jointly Administered) 

ORDER GRANTING PHILIP J. VON KAHLE AS ASSIGNEE OF 

LIBERTY POWER CORPORATION’S EX PARTE MOTION 

TO ALLOW ATTORNEY DANA QUICK TO APPEAR BY ZOOM AT 

THE HEARING CURRENTLY SCHEDULED FOR MAY 24, 2023 

THIS MATTER having come before the Court, without hearing, upon Philip J. von Kahle 

as Assignee of Liberty Power Corporation’s Ex Parte Motion to Allow Attorney Dana Quick to 

Appear by Zoom at the Hearing Currently Scheduled for May 24, 2023 [ECF No. ___] (the 

“Motion”).1

 The Court, having considered the Motion, and being otherwise fully advised in the 

premises, it is 

1

 Terms capitalized but not defined herein shall have the meanings ascribed to them in the Motion.

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ORDERED that: 

1. The Motion is GRANTED. 

2. Dana Quick is permitted to appear remotely via Zoom at the Hearing currently 

scheduled for May 24, 2023, at 1:30 p.m. (Prevailing Eastern Time). 

# # # 

Submitted by: 

Dana R. Quick, Esq. 

BAST AMRON LLP 

One Southeast Third Avenue, Suite 2410 

Miami, Florida 33131 

Telephone: (305) 379-7904 

Email: dquick@bastamron.com 

Copies to: 

Dana R. Quick, Esq. 

Dana Quick shall serve a copy of this order on all parties in interest, and shall file a 

certificate of service thereof. 

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