NOTICE OF APPEARANCE AND REQUEST FOR SERVICE OF

ALL NOTICES, PLEADINGS, ORDERS AND OTHER PAPERS – Page 1

IN THE UNITED STATES BANKRUPTCY COURT

FOR THE SOUTHERN DISTRICT OF FLORIDA

FORT LAUDERDALE DIVISION

www.flsb.uscourts.gov

IN RE: § CHAPTER 11

§

LIBERTY POWER HOLDINGS, LLC, § CASE NO. 21-13797-SMG

§

Debtor. §

§

NOTICE OF APPEARANCE AND REQUEST FOR SERVICE OF ALL

NOTICES, PLEADINGS, ORDERS AND OTHER PAPERS

PLEASE TAKE NOTICE that the undersigned counsel and the law firm of Munsch Hardt 

Kopf & Harr, P.C. hereby appear on behalf of the Electric Reliability Council of Texas, Inc.

(“ERCOT”) in the bankruptcy case (the “Bankruptcy Case”) of the above-captioned debtor and,

pursuant to section 1109(b) of title 11 of the United States Code and Rules 2002, 3017, 9007 and 

9010(b) of the Federal Rules of Bankruptcy Procedure, hereby requests that all notices given or 

required to be given in the Bankruptcy Case, and all papers served or required to be served in the 

Bankruptcy Case, be served upon the undersigned counsel at the following address:

Kevin M. Lippman

Munsch Hardt Kopf & Harr, P.C.

500 N. Akard Street, Suite 3800

Dallas, Texas 75201-6659

Telephone: (214) 855-7500

Facsimile: (214) 855-7584

E-mail: klippman@munsch.com

PLEASE TAKE FURTHER NOTICE that, pursuant to 11 U.S.C. § 1109(b) and Rules 

2002, 3017, 9007 and 9010 of the Federal Rules of Bankruptcy Procedure, the foregoing request 

includes notices and papers referred to in the Bankruptcy Rules and additionally includes, without 

limitation, motions, applications, complaints, demands, notices of motions, notices of applications, 

Case 21-13797-SMG Doc 32 Filed 04/23/21 Page 1 of 3
NOTICE OF APPEARANCE AND REQUEST FOR SERVICE OF

ALL NOTICES, PLEADINGS, ORDERS AND OTHER PAPERS – Page 2

notices of hearing, petitions, objections, claims, and all other pleadings or requests, whether formal 

or informal, whether written or oral, and whether transmitted or conveyed by mail, other 

commercial carrier, hand-delivery, facsimile, telegraph, telex, e-mail, telephone or otherwise.

PLEASE TAKE FURTHER NOTICE that this Notice of Appearance shall not be deemed 

or construed as ERCOT’s: (a) waiver of the right to have final orders in non-core matters entered 

only after de novo review by the United States District Court; (b) waiver of the right to trial by 

jury in any proceeding to which such right exists in the Bankruptcy Case or in any case, 

controversy, or proceeding related to the Bankruptcy Case; (c) waiver of the right to have the 

United States District Court withdraw the reference in any matter subject to mandatory or 

discretionary withdrawal; (d) waiver of the right to contest jurisdiction or appropriate venue in any 

related proceeding; or (e) waiver of any other rights, claims, actions, defenses, setoffs or 

recoupments which ERCOT has or may hereafter obtain, in law or in equity, all of which rights, 

claims, actions, defenses, setoffs and recoupments ERCOT hereby expressly reserves. 

Case 21-13797-SMG Doc 32 Filed 04/23/21 Page 2 of 3
NOTICE OF APPEARANCE AND REQUEST FOR SERVICE OF

ALL NOTICES, PLEADINGS, ORDERS AND OTHER PAPERS – Page 3

Dated: April 23, 2021 MUNSCH HARDT KOPF & HARR, P.C.

500 N. Akard Street, Suite 3800

Dallas, Texas 75201-6659

Telephone: (214) 855-7500

Facsimile: (214) 855-7584

E-mail: klippman@munsch.com

By: /s/ Kevin M. Lippman

Kevin M. Lippman

Texas Bar No. 00784479

ATTORNEYS FOR THE ELECTRIC RELIABILITY 

COUNCIL OF TEXAS, INC.

CERTIFICATE OF SERVICE

The undersigned hereby certifies that on the 23rd day of April, 2021, he caused a true and 

correct copy of the foregoing Notice of Appearance to be served electronically through the Court's 

ECF system upon all parties listed below.

 /s/ Kevin M. Lippman

Kevin M. Lippman

CM/ECF Service List

Paul J. Battista pbattista@gjb-law.com

Heather L. Harmon hharmon@gjb-law.com

Jordi Guso jguso@bergersingerman.com

Daniel N. Gonzalez dgonzalez@melandbudwick.com

Scott Andron sandron@boward.org

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

4837-0731-7222v.2 012761.00011

Case 21-13797-SMG Doc 32 Filed 04/23/21 Page 3 of 3