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UNITED STATES BANKRUPTCY COURT

SOUTHERN DISTRICT OF FLORIDA

MIAMI DIVISION

In Re:

AVA CELESTE BENJAMIN AKA AVA 

BENJAMIN AKA AVA CELESTE 

BENJAMIN,

Debtor.

/

Case No. 22-11124-AJC

Chapter 13

REQUEST FOR SPECIAL NOTICE AND SERVICE OF COPIES

TO: UNITED STATES BANKRUPTCY JUDGE, THE DEBTOR(S), AND ALL INTERESTED 

PARTIES

PLEASE TAKE NOTICE that ALDRIDGE PITE, LLP submits this Request for Special Notice 

and Service of Copies, for LoanCare, LLC and hereby requests special notice of all events relevant to the 

above-referenced bankruptcy and copies of all pleadings or documents filed in relation to the abovereferenced bankruptcy, including all pleadings or notices under Federal Rules of Bankruptcy Procedure, 

Rule 2002, the commencement of any adversary proceedings, the filing of any requests for hearing, 

objections, and/or notices of motion, or any other auxiliary filings, as well as notice of all matters which 

must be noticed to creditors, creditors committees and parties-in-interest and other notices as required by 

the United States Bankruptcy Code and Rules and/or Local Rules of the above-referenced bankruptcy 

court.

ALDRIDGE PITE, LLP, requests that for all notice purposes and for inclusion in the Master 

Mailing List in this case, the following address be used:

Jennifer Laufgas

ALDRIDGE PITE, LLP

Aldridge Pite, LLP

Fifteen Piedmont Center

3575 Piedmont Road, N.E., Suite 500

Atlanta, GA 30305

Neither this Request for Special Notice nor any subsequent appearance, pleading, claim, proof of 

claim, documents, suit, motion nor any other writing or conduct, shall constitute a waiver of the within 

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party's:

a. Right to have any and all final orders in any and all non-core matters entered only after de 

novo review by a United States District Court Judge;

b. Right to receive service pursuant to Fed. R. Civ. P. 4 made applicable to the instant 

proceeding by Fed. R. Bankr. P. 7004. This Request for Special Notice shall not operate as a confession 

and/or concession of jurisdiction. Moreover, the within party does not authorize Aldridge Pite, LLP, 

either expressly or impliedly through Aldridge Pite, LLP’s participation in the instant proceeding, to act 

as its agent for purposes of service under Fed. R. Bankr. P. 7004;

c. Right to trial by jury in any proceeding as to any and all matters so triable herein, whether 

or not the same be designated legal or private rights, or in any case, controversy or proceeding related 

hereto, notwithstanding the designation or not of such matters as "core proceedings" pursuant to 28

U.S.C. § 157(b)(2)(H), and whether such jury trial right is pursuant to statute or the United States 

Constitution;

d. Right to have the reference of this matter withdrawn by the United States District Court in 

any matter or proceeding subject to mandatory or discretionary withdrawal; and

e. Other rights, claims, actions, defenses, setoffs, recoupments or other matters to which this 

party is entitled under any agreements at law or in equity or under the United States Constitution.

Dated: February 17, 2022 ALDRIDGE PITE, LLP

/s/ Jennifer Laufgas

Jennifer Laufgas (SBN 56181)

jlaufgas@aldridgepite.com

Aldridge Pite, LLP

Fifteen Piedmont Center

3575 Piedmont Road, N.E., Suite 500

Atlanta, GA 30305

Phone: (404) 994-7400

Fax: (619) 590-1385

Case 22-11124-AJC Doc 17 Filed 02/17/22 Page 2 of 2