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’ EXPEDITED SECOND OMNIBUS MOTION FOR ENTRY 

OF AN ORDER (I) AUTHORIZING THE REJECTION OF CERTAIN NONCUSTOMER EXECUTORY CONTRACTS AND (II) SETTING BAR DATE TO FILE 

REJECTION DAMAGE CLAIMS 

(Expedited Hearing Requested) 

Liberty Power Holdings, LLC (“Holdings”), Liberty Power District of Columbia, LLC 

(“Liberty District of Columbia”), LPT, LLC (“LPT”) and Liberty Power Maryland, LLC (“Liberty 

Maryland”)(collectively, the “Debtors”), by and through their undersigned counsel, hereby submit 

this motion (the “Motion”) for entry of an order (the “Order”) pursuant to sections 105(a) and 365 

of title 11 of the United States Code (the “Bankruptcy Code”), Rule 6006 of the Federal Rules of 

Bankruptcy Procedure (the “Bankruptcy Rules”) and Rules 6006-1 and 9013-1(a) of the Local 

Rules for the Southern District of Florida (the “Local Rules”): (i) authorizing the Debtors to reject 

those certain non-customer executory contracts as described on Exhibit “A” attached hereto; and 

(ii) setting a bar date for the filing of claims under 11 U.S.C.§§ 365(g) and/or 502(g) based upon 

the rejection of such non-customer executory contracts. In support of this Motion, the Debtors 

respectfully state as follows: 

Case 21-13797-SMG Doc 621 Filed 04/11/22 Page 1 of 14
JURISDICTION AND VENUE 

1. This Court has jurisdiction to consider this Motion pursuant to 28 U.S.C. §§ 157 

and 1334. This is a core proceeding pursuant to 28 U.S.C. § 157(b). Venue of the Debtors’ 

bankruptcy cases and this Motion in this district is proper pursuant to 28 U.S.C. §§ 1408 and 1409. 

2. The statutory predicates for the relief requested herein are sections 105(a) and 365 

of Bankruptcy Code, Bankruptcy Rule 6006 and Rules 6006-1 and 9013-1 of the Local Rules. 

RELEVANT BACKGROUND 

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”), the Subsidiary Debtors each 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. For a detailed description of the Debtors and their operations, the Debtors 

respectfully refer the Court and parties in interest to the Declaration of Bob Butler, Chief 

Restructuring Officer, in Support of the Chapter 11 Petition and First Day Motions (the “First Day

Declaration”)[ECF No. 10] and the Chapter 11 Case Management Summary [ECF No. 15]. 

Case 21-13797-SMG Doc 621 Filed 04/11/22 Page 2 of 14
SALE PROCESS 

7. On September 10, 2021 the Court entered the Order (I) Approving Sale of the 

Purchased Assets Free and Clear of Liens, Claims, Encumbrances, and Other Interest, (II) 

Authorizing Assumption and Assignment of Certain Executory Contracts and Unexpired Lease in 

Connection Therewith and (III) Granting Relief (“Sale Order”) [ECF NO. 385] approving, among 

other things, the sale of substantially all of the Debtors’ assets to NRG Energy, Inc. (“NRG” or 

“Buyer”). 

8. On September 22, 2021, the Debtors and the Buyer closed on the sale of the 

Purchased Assets pursuant to the terms of the Asset Purchase Agreement and the Sale Order. In 

connection therewith, the Debtors and the Buyer have been diligently working to effect a transition 

and transfer of the customer contracts to the Buyer, including by providing all required notices to 

customers and regulatory agencies, and by complying with all applicable laws related thereto. 

9. The Debtors have completed the transition process in Texas, and are continuing to 

work on such transition in the East. In addition, the Debtors continue to serve certain remaining 

customers in Texas that were not sold to the Buyer and were not the subject of a rejection or 

termination motion. 

REJECTION OF SELECTED NON-CUSTOMER EXECUTORY CONTRACTS 

10. Prior to the Petition Date, the Debtors were parties1 to certain non-customer 

contracts for goods and services including, but not limited to, customer creditworthiness 

determination, customer account collections, software subscriptions and consulting services, 

                                                            

1

 Certain of the Non-Customer Contracts are in the name of Liberty Power Corporation (“LPC”), the Debtors’ parent 

company, or simply in the name of “Liberty Power.” The Debtors have historically paid certain obligations due under 

the generically named and LPC’s Non-Customer Contracts and therefore, in an abundance of caution, they are 

included on Exhibit “A” and referenced accordingly. The Debtors reserve all rights with respect to whether or not 

any Non-Customer Contract is indeed a contract of the Debtors for purposes of rejection damages associated therewith. 

Case 21-13797-SMG Doc 621 Filed 04/11/22 Page 3 of 14
among others (collectively, the “Non-Customer Contracts”). The Non-Customer Contracts are 

identified by Exhibit “A” attached hereto. 

11. The Debtors have determined, in the reasonable exercise of their business 

judgment, that the Non-Customer Contracts no longer serve any business purpose for the Debtors 

and are burdensome to the Debtors’ estates. As a result, the Debtors have concluded that the best 

course of action for the Debtors and their bankruptcy estates is to reject the Non-Customer 

Contracts. 

 RELIEF REQUESTED AND BASIS THEREFOR 

12. By this Motion, the Debtors seek entry of an Order (i) authorizing the Debtors to 

reject the Non-Customer Contracts, (ii) waiving the requirements of Bankruptcy Rule 6006(f)(6), 

and (iii) setting a bar date for the assertion of claims under 11 U.S.C.§§ 365(g) and/or 502(g) based 

upon the rejection of such Non-Customer Contracts. 

13. The Debtors have determined that in light of the sale of substantially all of the 

Debtors’ assets to the Buyer pursuant to the Stalking Horse Agreement, the Non-Customer 

Contracts provide no further benefit to the Debtors’ estates and create unnecessary and 

burdensome expenses for the Debtors’ estates. The Debtors have marketed the Non-Customer 

Contracts for sale but have determined that no meaningful value would be realized by the Debtors 

if the Non-Customer Contracts were assumed and assigned to third parties. In fact, the Debtors 

are not currently aware of any cost effective transaction with a third-party buyer for the sale of the 

Non-Customer Contracts. 

14. Accordingly, the Debtors assert that rejection of the Non-Customer Contracts is in 

the best interest of the Debtors and their estates. 

Case 21-13797-SMG Doc 621 Filed 04/11/22 Page 4 of 14
15. In addition, the Debtors propose that customers under the Non-Customer Contracts 

have a period of 30 days after the date of an Order granting this Motion to file any claims for 

damages resulting from the rejection of their contracts hereunder. 

16. The Debtors have conferred with their senior secured lender, Boston Energy 

Trading and Marketing, LLC (“BETM”) concerning the relief requested herein and BETM has no 

objection. 

17. Therefore, based on the above, the Debtors assert that the relief requested herein is 

in their best interests and in the best interests of their bankruptcy estates. 

LEGAL AUTHORITY 

A. Rejection of the Non-Customer Contracts Constitutes a Sound Exercise of the 

Debtors’ Business Judgment. 

18. Section 365(a) of the Bankruptcy Code allows a debtor, subject to approval of the 

bankruptcy court, to assume or reject any executory contract or unexpired lease. See Stewart Title 

Guaranty Co. v. Old Republic National Title Insurance Co., 83 F.3d 735, 741 (5th Cir. 1996). 

“‘This provision allows a [debtor] to relieve the bankruptcy estate of burdensome agreements 

which have not been completely performed.’” Stewart Title, 83 F.3d at 741 (quoting In re Murexco 

Petroleum, Inc., 15 F.3d 60, 62 (5th Cir. 1994)). A debtor’s decision to assume or reject an 

executory contract or unexpired lease is subject to the “business judgment” test. In re Gardinier, 

Inc., 831 F.2d 974, 976 n.2 (11th Cir. 1987); In re Chira, 367 B.R. 888, 898 (S.D. Fla. 2007); In 

re Prime Motors, Inc., 124 B.R. 378, 381 (Bankr. S.D. Fla. 1991). The sole inquiry is whether 

assumption or rejection will benefit this estate. Id.; see also In re Hawaii Dimensions, Inc., 47 B.R. 

425, 427 (D. Haw. 1985) (“[u]nder the business judgment test, a court should approve a debtor’s 

proposed rejection if such rejection will benefit the estate”).

Case 21-13797-SMG Doc 621 Filed 04/11/22 Page 5 of 14
19. In applying the “business judgment” test, courts show great deference to a debtor’s 

decision to assume or reject an executory contract. See Summit Land Co. v. Allen (In re Summit 

Land Co.), 13 B.R. 310, 315 (Bankr. D. Utah 1981) (absent extraordinary circumstances, court 

approval of debtor’s decision to assume or reject an executory contract “should be granted as a 

matter of course”). As long as the decision to assume or reject is a reasonable exercise of business 

judgment, courts should approve the assumption or rejection of an executory contract or unexpired 

lease. See, e.g., NLRB v. Bildisco and Bildisco, 465 U.S. 513, 523 (1984); Group of Institutional 

Investors v. Chicago M. St. P. & P. R. R. Co., 318 U.S. 523 (1943). 

20. The Debtors, in their sound business judgment, have determined that rejection of 

the Non-Customer Contracts is in the best interests of the Debtors’ estates. As set forth above, the 

Non-Customer Contracts are no longer necessary for or beneficial to the Debtors’ ongoing 

businesses, and they create unnecessary and burdensome expenses for the Debtors’ estates. In 

addition, the Debtors have determined that no meaningful value would be realized by the Debtors 

if the Non-Customer Contracts were assumed and assigned to third parties. Accordingly, the NonCustomer Contracts should be rejected. 

B. Bar Date Notice 

21. The Debtors’ noticing and claims agent, Stretto, will serve a copy of the Order on 

this Motion to each counterparty under the Non-Customer Contracts. Stretto will include with the 

Order information as to the address of the claims agent for the filing of any proof of claim based 

on the proposed rejection of the Non-Customer Contracts (the “Bar Date Notice”). 

22. The Debtors also propose that: ANY PROOF OF CLAIM FOR DAMAGES 

ARISING FROM THE REJECTION MUST BE FILED WITH THE CLAIMS AGENT ON 

OR BEFORE THE LATEST OF: (I) THE TIME FOR FILING A PROOF OF CLAIM 

Case 21-13797-SMG Doc 621 Filed 04/11/22 Page 6 of 14
PURSUANT TO BANKRUPTCY RULE 3002(C); OR (II) 30 DAYS AFTER THE DATE 

OF AN ORDER ON THIS MOTION APPROVING THE REJECTION OF THE NONCUSTOMER CONTRACTS.

Reservation of Rights 

23. Nothing contained herein is intended or should be construed as prejudicing any 

rights the Debtors may have to dispute or contest (i) whether any of the Non-Customer Contracts 

is actually an executory contract or unexpired lease that is subject to assumption or rejection under 

section 365 of the Bankruptcy Code, or (ii) the amount of, or basis for, any claims asserted against 

the Debtors arising in connection with the rejection of the Non-Customer Contract, or as an 

admission as to the validity or priority of any claim against the Debtors. Further, nothing contained 

herein is intended or should be construed as an admission of the validity of any claim against the 

Debtors, a waiver of the Debtors’ or any other party’s rights to dispute any claim, or an approval 

or assumption of any agreement, contract, or lease under Bankruptcy Code section 365 other than 

those Non-Customer Contracts that are subject to this Motion. 

WHEREFORE, the Debtors respectfully request entry of an Order: (i) approving the 

rejection of the Non-Customer Contracts set forth on Exhibit “A” attached hereto; (ii) waiving 

the requirements of Bankruptcy Rule 6006(f)(6) as set forth herein; (iii) setting a bar date for the 

assertion of claims under 11 U.S.C. §§ 365(g) and/or 502(g) based upon the rejection of the NonCustomer Contracts for 30 days after the date of such Order; and (iv) granting such other relief as 

is just and proper. 

Case 21-13797-SMG Doc 621 Filed 04/11/22 Page 7 of 14
Dated: April 11, 2022 

Respectfully Submitted, 

 GENOVESE JOBLOVE & BATTISTA, P.A. 

 Attorneys 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 

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

 

Case 21-13797-SMG Doc 621 Filed 04/11/22 Page 8 of 14
EXHIBIT “A” 

Case 21-13797-SMG Doc 621 Filed 04/11/22 Page 9 of 14
Liberty Power Holdings, LLC

Non-Customer Executory Contracts

Counterparty Debtor Counterparty Description of Contract Counte

1.) ABB Enterprise Software Liberty Power Holdings, LLC Licensed software and equipment 1021 Main Campus Dr R2.) Accept Software Liberty Power Corporation, LLC Licensed software and professional services 3979 Freedom Circle Dri

95054

3.) Achieve CEO Inc Liberty Power Holdings, LLC Business acquisition consulting services 10800 Biscayne Blvd, Mi4.) Adapt2 Liberty Power Corporation, LLC Master service agreement for independent 

contractor

9821 Katy Frewway, Suit

5.) Administaff Liberty Power Corporation, LLC Human resources and administrative services 19001 Crescent Springs 

6.) Adorno & Yoss Liberty Power Holdings, LLC Law firm for volume collection matters 1625 S. Congress Ave, S

33445

7.) Affiliated Power Purchasers 

International

Liberty Power Corporation, LLC Sponsorship agreement for research programs 224 Phillip Morris Dr, Sui

8.) AFJ Systems Liberty Power Corporation, LLC Collection and representation services 17350 State Highway 24

77064

9.) Amerex Liberty Power Holdings, LLC Energy commodities products and financial 

derivatives broker

1 Sugar Creek Blvd, Suit

10.) Ampion Liberty Power Corporation, LLC Customer acquisition services 31 St. James Ave, Bosto11.) Anchor Computer, Inc. Liberty Power Holdings, LLC Email data services 1900 New Highway Farm12.) Applied Metering Technologies Liberty Power Holdings, LLC Meter installation, maintenance, telephone 

communication services, and related meter services

9244 Bermudez St, Pico 

13.) AssureSign Liberty Power Corporation, LLC Electronic signature services 220 E Central Parkway, S

FL 32701

14.) AT&T Liberty Power Holdings, LLC Telecommunications services 1 AT&T Way, Bedminste15.) Aurea Energy Solutions Liberty Power Corporation, LLC External hard drive storage 401 Congress, Suite 26516.) Baker Ripley LPT, LLC Comprehensive energy assistance program

agreement

PO Box 271389, Housto

17.) Bendixen Liberty Power Corporation, LLC Sales channel research services 3250 Mary Street, Suite #18.) Bentek Liberty Power Corporation, LLC Market analytics research services 32045 Castle Cort, Suite 19.) Brainshark Inc Liberty Power Corporation, LLC Professional services agreement 130 Turner St, Bldg. 1, S

20.) Brazos Valley Community 

Action Program

LPT, LLC Comprehensive energy assistance program 

agreement

1733 Briarcrest Dr, Suite 

21.) Cameo Solutions Inc Liberty Power Corporation, LLC Licenses proprietary software 9990 International Blvd, C

22.) Carmazzi Global Solutions Liberty Power Corporation, LLC Telephonic interpretation services 65 Quinta Court, Suite G

23.) Cass Information Systems Liberty Power Corporation, LLC Accounts payable and related analysis report 

and data processing services

13001 Hollenberg Dr, St. 

24.) Champion Solutions Group Liberty Power Holdings, LLC Software and equipment services 10100 Reunion Place, Su

25.) Cloud Consulting Services Liberty Power Corporation, LLC Salesorce optimization consulting services 1901 Brickell Ave, Suite 26.) Combined Community Action LPT, LLC Comprehensive energy assistance program 

agreement

165 W Austin, Giddings, 

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Case 21-13797-SMG Doc 621 Filed 04/11/22 Page 10 of 14
Liberty Power Holdings, LLC

Non-Customer Executory Contracts

Counterparty Debtor Counterparty Description of Contract Counte

27.) Communico Liberty Power Corporation, LLC Customer service training and consulting 

services

19 Ludlow Rd, Suite 102

28.) Cornerstone OnDemand Liberty Power Corporation, LLC Cloud subscription services 1601 Cloverfield Blvd, Su

CA 90404

29.) Correlate Liberty Power Corporation, LLC Market and sell energy management as a 

service

3162 Ibis Lane, San Dieg

30.) CoStar Realty Information Inc. Liberty Power Corporation, LLC Commercial real estate information services 1331 L Street, NW Wash

31.) Creative Cash Flow Solutions Liberty Power Holdings, LLC Data processiong services 221 Broadway, Ground F

32.) Credit Risk Monitor Liberty Power Holdings, LLC Proprietary internet-based news and financial 

analysis service

704 Executive Blvd # A, V

33.) Cypress Executive Associates Liberty Power Corporation, LLC Lease agreement 2255 Glades Road, Suite 

34.) Dun & Bradstreet, Inc Liberty Power Corporation, LLC Commercial data and analytics 5335 Gate Parkway, Jac35.) DataBank Inc Liberty Power Corporation, LLC Customer order verification 7666 E 61st St, Suite 24036.) Duke Energy Ohio Liberty Power Holdings, LLC Customer choice program 139 E Fourth St, Cincinn37.) EMC Corporation Liberty Power Holdings, LLC Software and equipment services 176 South St, Hopkinton38.) Energy GPS Liberty Power Holdings, LLC License subscription agreement 2512 SE 25TH Ave Ste 339.) Equifax Information Services Liberty Power Holdings, LLC Database services P.O. Box 740123, Atlanta40.) ESAI Power LLC Liberty Power Corporation, LLC Market analysis reporting 401 Edgewater Place, Su41.) Everge Group Liberty Power Holdings, LLC Software consulting services 4965 Preston Park Blvd # 42.) Experian Marketing Solutions Liberty Power Holdings, LLC Market services and business reports 475 Anton Blvd, Costa M

43.) Garcia & Company Liberty Power Corporation, LLC Financial and business consulting services 1200 Brickell Ave, Suite 844.) GlobalView Liberty Power Corporation, LLC License and data services 100 South Wacker Dr, Su45.) GP Energy Management. LLC Liberty Power Holdings, LLC Software and license services 131 Varick St, Suite 1008

46.) Greast Eastern Energy Liberty Power Holdings, LLC Consulting agreement for marketing and 

promotion

1515 Sheepshead Bay R

47.) Greater East Texas 

Community Action Program

LPT, LLC Comprehensive energy assistance program 

agreement

PO Box 631938, 114 W H75961

48.) Greenberg, Grant & Richards, 

Inc

Liberty Power Holdings, LLC Accounts receivable collections 5858 Westheimer Rd, Su

49.) Gridpoint Liberty Power Holdings, LLC Energy reseller agreement 11951 Freedom Dr, Suite 50.) HCL Technologies Liberty Power Corporation, LLC Web page development 330 Potrero Ave, Sunnyv51.) Hidalgo County LPT, LLC Comprehensive energy assistance program 

agreement

PO Box 204, Edinburg, T

52.) Hill Country Community Action 

Association

LPT, LLC Comprehensive energy assistance program 

agreement

2905 W Wallace, PO Box 

53.) Ideal Dialogue Liberty Power Corporation, LLC Professional services agreement 17804 N US Highway 4154.) Infogroup Liberty Power Holdings, LLC Data licensing, processing, and storage 1020 E 1st St, Papillion, 55.) Interactive Media Liberty Power Holdings, LLC Digital media marketing and technology 111 E Hargett St, Raleigh

2 of 5

Case 21-13797-SMG Doc 621 Filed 04/11/22 Page 11 of 14
Liberty Power Holdings, LLC

Non-Customer Executory Contracts

Counterparty Debtor Counterparty Description of Contract Counte

56.) InterfaceIT Operations Pty Ltd Liberty Power Holdings, LLC IT subscription services 2200 Colorado Ave, San57.) Ista North America Liberty Power Holdings, LLC Billing services 1325 Northmeadow Pkw58.) IVG Energy Liberty Power Holdings, LLC Energy commodities products and financial 

derivatives broker

20 E Greenway Plaza, S

59.) KB Synergy Liberty Power Corporation, LLC Direct mail and email services 5739 Kanan Road, Suite 60.) Kema Inc Liberty Power Corporation, LLC Energy market research and strategic advice 67 South Bedford St, Sui

61.) Kforce Liberty Power Corporation, LLC Consulting placement provider 1001 East Palm Ave, Tam62.) L1BRE LPC Liberty Power Corporation, LLC Customer support service agreement 95 Merrick Way, Suite 3063.) LED Plus Liberty Power Holdings, LLC Mobile app licensing and equipment 1 Metrotech Center North

11201

64.) Level 3 Communications LLC Liberty Power Corporation, LLC IP transit services 121 Champion Way, Can65.) Lexis Nexis, a Division of Ree 

Elsevier Inc

Liberty Power Corporation, LLC Market analytics research services 230 Park Ave #7, New Y

66.) Lockerman Studios Liberty Power Corporation, LLC Video and film design and production services 4020 Butler St, Pittsburg

67.) Maintrax Consulting Liberty Power Holdings, LLC Speech analytics consulting services PO Box 216, Sandia, MN 68.) Markit Totem Liberty Power Corporation, LLC Market valuation services 4th Floor, Ropemaker Pla

EC2Y 9LY

69.) Microsoft Liberty Power Corporation, LLC Business and services agreement 1 Microsoft Way, Redmo70.) Mpell Solutions Liberty Power Holdings, LLC Sales and marketing campaign 3142 Tiger Run Ct, Suite 71.) Multi Security Services Liberty Power Corporation, LLC Software application development and 

maintenance

14629 SW 104th St, Suit

72.) New Energy Associates Liberty Power Corporation, LLC Software services 400 Interstate North Pkw

30339

73.) New Harbor Double Liberty Power Corporation, LLC Financial advisory and investment banking 

services

546 Fifth Ave, 23rd Floor

74.) Ntirety Liberty Power Holdings, LLC Remote database administration 980 Washingston St, Sui75.) Ocean County Cooperative 

Pricing Syst.

Liberty Power Holdings, LLC Cooperative pricing system 101 Hooper Ave, Toms R

76.) Olameter Corp Liberty Power Holdings, LLC MDMA services for interval meters 2212 Arlington Downs Rd

76011

77.) Open Access Technology 

International Inc

Liberty Power Corporation, LLC IT services 3660 Technology DriveM

78.) Opportunities for Williamson & 

Burnett Counties

Liberty Power Corporation, LLC Comprehensive energy assistance program 

agreement

604 High Tech Dr, Georg

79.) Oracle Liberty Power Corporation, LLC Software and product services 500 Oracle Parkway, Red80.) Original Impressions Liberty Power Corporation, LLC Website design and SEO 2965 WEST CORPORAT

WESTON, FL 33331

81.) Pariveda Solutions Inc Liberty Power Holdings, LLC Software and technology consulting 24 Greenway Plaza, Suit

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Case 21-13797-SMG Doc 621 Filed 04/11/22 Page 12 of 14
Liberty Power Holdings, LLC

Non-Customer Executory Contracts

Counterparty Debtor Counterparty Description of Contract Counte

82.) PCI Liberty Power Holdings, LLC Print and mail services 3406 SW 26th Terrace, F83.) Peak 10 Liberty Power Corporation, LLC IT and data services 5301 NW 33rd Ave, Fort 84.) Peregrine Solutions LLC (Aime 

Leon)

Liberty Power Holdings, LLC IT services 7938 Stirling Bridge Blvd

85.) Perfect Commerce Liberty Power Holdings, LLC Telecommunications services 1 Bayport Way Ste 120 N86.) Plantek Liberty Power Holdings, LLC IT services 6030 Daybreak Circle, S

21029

87.) PLATTS - McGraw-Hill 

Companies, Inc.

Liberty Power Corporation, LLC Energy commodity data and services 2 Penn Plaza, New York

88.) Possible Now Liberty Power Corporation, LLC intermodal ported telephone ID service 4400 River Green Pkwy, 

89.) Premier Calls Liberty Power Holdings, LLC Customer care and retention support 1350 Churchill Rd, West 90.) Presidio Technology Capital Liberty Power Corporation, LLC License and software lease 2 Sun Ct, Norcross, GA 391.) Protection Plus Solutions Liberty Power Corporation, LLC Consumer credit reporting services 696 San Ramon Valley B92.) Protiviti Liberty Power Holdings, LLC Financial advisory and consulting services 1051 East Carry St, Suite 

93.) Rocket Science, LLC Liberty Power Corporation, LLC Risk analysis consulting services 75 Arlington Street, Bosto94.) Rolling Plains Management 

Corporation

LPT, LLC Comprehensive energy assistance program 

agreement

PO Box 490 Crowell, TX 

95.) Salem Media Representatives Liberty Power Corporation, LLC Radio advertising agreement 6400 N Beltine Rd, Suite 

96.) Saxon Business Systems Liberty Power Corporation, LLC Equipment lease PO Box 4908, Miami Lak97.) Solutions@MBAF, LLC Liberty Power Corporation, LLC Computer software solutions 1001 Brickell Bay Dr, 16t

98.) Speedeon Data Liberty Power Holdings, LLC Landline phone data services 5875 Landerbrook Dr, Su99.) Suddath Liberty Power Corporation, LLC Warehouse receipt & storage contract 5301 Polk Blvd #14, Hou100.) Sungard Liberty Power Corporation, LLC Software and implementation services 680 East Swedesford Ro101.) SW Consulting (Itivx) Liberty Power Corporation, LLC Technology development services 521 Alafaya Woods Blvd

102.) Talk2Rep Liberty Power Holdings, LLC Customer care and retention support 8795 W McNab Rd, Suite 103.) Technology Value Financial 

LLC

Liberty Power Corporation, LLC Equipment lease 1800 Paxton St, Harrisbu

104.) Telcordia Technologies Liberty Power Holdings, LLC intermodal ported telephone ID service 100 Somerset Corporate 105.) Texoma Council of 

Governments

LPT, LLC Comprehensive energy assistance program 

agreement

1117 Gallagher Dr, Sher

106.) The C&L Group Liberty Power Corporation, LLC IT consulting services 380 Lexington Ave, New 107.) The Sales Verification 

Company

Liberty Power Corporation, LLC Third party verification services 13100 56th Court, Suite 

108.) Thorndike Landing LLC Liberty Power Corporation, LLC Business assessment and evaluation 68 Thorndike St, Dunstab109.) TLV Consulting LLC Liberty Power Corporation, LLC Technology research and consulting 4447 N Central Expressw

75205

110.) TP Verification Liberty Power Corporation, LLC Third party verification services 262 Capote CT E, Sever111.) TruMarx Data Partners, Inc. Liberty Power Corporation, LLC Electronic transaction services 130 S Jefferson, Suite 10

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Liberty Power Holdings, LLC

Non-Customer Executory Contracts

Counterparty Debtor Counterparty Description of Contract Counte

112.) Uptrending Growth Services, 

Inc.

Liberty Power Corporation, LLC Third party verification services 1255 Cleveland St, 4th F

33755

113.) Valassis Direct Mail Liberty Power Corporation, LLC Advertising services 19975 Victor Parkway, L114.) Viasyn Inc Liberty Power Corporation, LLC Scheduling and settlements services 2680 Bishop Dr, Suite 27115.) VoiceLog Liberty Power Corporation, LLC Telephonic interpretation services 7411 John Smith Dr, Suit

116.) West Texas Opportunities Inc LPT, LLC Comprehensive energy assistance program 

agreement

PO Box 1308, Lamesa, T

117.) Wildfire Interactive Inv Liberty Power Corporation, LLC Social media services 1600 Amphitheatre Pkwy

118.) Wipfli Liberty Power Corporation, LLC Software license and hardware 10000 W Innovation Dr, S119.) Wisdomified Consulting Liberty Power Holdings, LLC Marketing consulting services 4470 Banyan Trails Dr, C

120.) ZoomInfo Liberty Power Holdings, LLC Subscription services agreements 170 Tracer Ln, Walthan, 

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