UST Form 11-MOR (12/01/2021) 1

UNITED STATES BANKRUPTCY COURT

SOUTHERN DISTRICT OF FLORIDA

FORT LAUDERDALE DIVISION

In Re. LIBERTY POWER HOLDINGS, LLC, 

LPT, LLC, 

LIBERTY POWER MARYLAND, LLC 

Debtor(s)

§ 

§ 

§ 

§ 

Case No. 21-13797

Lead Case No. 21-13797

Jointly Administered

Monthly Operating Report Chapter 11

Reporting Period Ended: 04/30/2022 Petition Date: 04/20/2021

Months Pending: 13 Industry Classification: 4 9 1 1

Reporting Method: Accrual Basis Cash Basis

Debtor's Full-Time Employees (current): 0

Debtor's Full-Time Employees (as of date of order for relief): 0

Supporting Documentation (check all that are attached):

(For jointly administered debtors, any required schedules must be provided on a non-consolidated basis for each debtor)

Statement of cash receipts and disbursements

Balance sheet containing the summary and detail of the assets, liabilities and equity (net worth) or deficit 

Statement of operations (profit or loss statement)

Accounts receivable aging

Postpetition liabilities aging

Statement of capital assets

Schedule of payments to professionals

Schedule of payments to insiders

All bank statements and bank reconciliations for the reporting period 

Description of the assets sold or transferred and the terms of the sale or transfer

Signature of Responsible Party Printed Name of Responsible Party

Date

Address

/s/ Victoria M. Dusch

05/20/2022

Victoria M. Dusch

2100 W. Cypress Creek Rd., Ste 130 

Ft. Lauderdale, FL 33309

STATEMENT: This Periodic Report is associated with an open bankruptcy case; therefore, Paperwork Reduction Act exemption 5 C.F.R. 

§ 1320.4(a)(2) applies.

Case 21-13797-SMG Doc 682 Filed 05/24/22 Page 1 of 12
UST Form 11-MOR (12/01/2021) 2

Debtor's Name LIBERTY POWER HOLDINGS, LLC, 

LPT, LLC, 

Case No. 21-13797

Part 1: Cash Receipts and Disbursements Current Month Cumulative

a. Cash balance beginning of month $3,574,247

b. Total receipts (net of transfers between accounts) $1,152,077 $237,007,709

c. Total disbursements (net of transfers between accounts) $1,879,721 $250,416,960

d. Cash balance end of month (a+b-c) $2,846,603

e. Disbursements made by third party for the benefit of the estate $0 $0

f. Total disbursements for quarterly fee calculation (c+e) $1,879,721 $250,416,960

Part 2: Asset and Liability Status Current Month

(Not generally applicable to Individual Debtors. See Instructions.)

a. Accounts receivable (total net of allowance) $-594,571

b. Accounts receivable over 90 days outstanding (net of allowance) $0

c. Inventory (Book Market Other (attach explanation)) $0

d Total current assets $6,143,882

e. Total assets $15,316,241

f. Postpetition payables (excluding taxes) $33,796,779

g. Postpetition payables past due (excluding taxes) $0

h. Postpetition taxes payable $813,675

i. Postpetition taxes past due $0

j. Total postpetition debt (f+h) $34,610,454

k. Prepetition secured debt $109,357,255

l. Prepetition priority debt $0

m. Prepetition unsecured debt $70,433,205

n. Total liabilities (debt) (j+k+l+m) $214,400,914

o. Ending equity/net worth (e-n) $-199,084,673

Part 3: Assets Sold or Transferred Current Month Cumulative

a. Total cash sales price for assets sold/transferred outside the ordinary 

course of business $0 $33,646,276

b. Total payments to third parties incident to assets being sold/transferred 

outside the ordinary course of business $0 $0

c. Net cash proceeds from assets sold/transferred outside the ordinary 

course of business (a-b) $0 $33,646,276

Part 4: Income Statement (Statement of Operations) Current Month Cumulative

(Not generally applicable to Individual Debtors. See Instructions.)

a. Gross income/sales (net of returns and allowances) $-648,114

b. Cost of goods sold (inclusive of depreciation, if applicable) $469,924

c. Gross profit (a-b) $-1,118,038

d. Selling expenses $498,686

e. General and administrative expenses $515,959

f. Other expenses $-4,565,489

g. Depreciation and/or amortization (not included in 4b) $209,126

h. Interest $818,632

i. Taxes (local, state, and federal) $0

j. Reorganization items $627,066

k. Profit (loss) $777,983 $-18,229,456

Case 21-13797-SMG Doc 682 Filed 05/24/22 Page 2 of 12
UST Form 11-MOR (12/01/2021) 3

Debtor's Name LIBERTY POWER HOLDINGS, LLC, 

LPT, LLC, 

Case No. 21-13797

Part 5: Professional Fees and Expenses

 Approved 

Current Month

Approved 

Cumulative

Paid Current 

Month

Paid 

Cumulative

a. Debtor's professional fees & expenses (bankruptcy) Aggregate Total $0 $0 $551,824 $6,938,739

Itemized Breakdown by Firm

Firm Name Role

i Berkeley Research Group Financial Professional $0 $0 $378,059 $4,869,418

ii Stretto Other $0 $0 $36,316 $736,657

iii Genovese Joblove & Battista Lead Counsel $0 $0 $137,449 $1,332,664

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Case 21-13797-SMG Doc 682 Filed 05/24/22 Page 3 of 12
UST Form 11-MOR (12/01/2021) 4

Debtor's Name LIBERTY POWER HOLDINGS, LLC, 

LPT, LLC, 

Case No. 21-13797

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Case 21-13797-SMG Doc 682 Filed 05/24/22 Page 4 of 12
UST Form 11-MOR (12/01/2021) 5

Debtor's Name LIBERTY POWER HOLDINGS, LLC, 

LPT, LLC, 

Case No. 21-13797

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b. Debtor's professional fees & expenses (nonbankruptcy) Aggregate Total $0 $0 $19,333 $584,505

Itemized Breakdown by Firm

Firm Name Role

i Marketwise Consulting Other $0 $0 $0 $55,900

ii Eckert Seamans Special Counsel $0 $0 $9,446 $30,610

iii Holland and Knight Special Counsel $0 $0 $4,887 $169,373

iv Sidley Austin Special Counsel $0 $0 $0 $74,480

v Robinson + Cole Special Counsel $0 $0 $0 $115,094

vi Greenberg Grants & Richards Other $0 $0 $0 $405

vii I.C. Systems Other $0 $0 $0 $4,969

viii L.J. Ross Associates Other $0 $0 $0 $5,445

ix Topping Kessler & Co Other $0 $0 $0 $45,629

x Greene Hurlocker Other $0 $0 $0 $128

xi Law Office of Miguel Huertas Other $0 $0 $0 $2,621

xii Husch Blackwell, LLP Other $0 $0 $0 $3,742

xiii Patterson Belknap Webb & Tyl Other $0 $0 $0 $71,108

xiv Monticello Consulting Group Other $0 $0 $5,000 $5,000

Case 21-13797-SMG Doc 682 Filed 05/24/22 Page 5 of 12
UST Form 11-MOR (12/01/2021) 6

Debtor's Name LIBERTY POWER HOLDINGS, LLC, 

LPT, LLC, 

Case No. 21-13797

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Case 21-13797-SMG Doc 682 Filed 05/24/22 Page 6 of 12
UST Form 11-MOR (12/01/2021) 7

Debtor's Name LIBERTY POWER HOLDINGS, LLC, 

LPT, LLC, 

Case No. 21-13797

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Case 21-13797-SMG Doc 682 Filed 05/24/22 Page 7 of 12
UST Form 11-MOR (12/01/2021) 8

Debtor's Name LIBERTY POWER HOLDINGS, LLC, 

LPT, LLC, 

Case No. 21-13797

xcix

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c. All professional fees and expenses (debtor & committees) $0 $0 $571,157 $7,523,234

Part 6: Postpetition Taxes Current Month Cumulative

a. Postpetition income taxes accrued (local, state, and federal) $0 $0

b. Postpetition income taxes paid (local, state, and federal) $0 $0

c. Postpetition employer payroll taxes accrued $0 $0

d. Postpetition employer payroll taxes paid $0 $0

e. Postpetition property taxes paid $0 $0

f. Postpetition other taxes accrued (local, state, and federal) $114,862 $7,673,162

g. Postpetition other taxes paid (local, state, and federal) $95,532 $6,976,873

Part 7: Questionnaire - During this reporting period:

a. Were any payments made on prepetition debt? (if yes, see Instructions) Yes No

b. Were any payments made outside the ordinary course of business Yes No

without court approval? (if yes, see Instructions)

c. Were any payments made to or on behalf of insiders? Yes No

d. Are you current on postpetition tax return filings? Yes No

e. Are you current on postpetition estimated tax payments? Yes No

f. Were all trust fund taxes remitted on a current basis? Yes No

g. Was there any postpetition borrowing, other than trade credit? Yes No

(if yes, see Instructions)

h. Were all payments made to or on behalf of professionals approved by 

the court?

Yes No N/A

i. Do you have: Worker's compensation insurance? Yes No

If yes, are your premiums current? Yes No N/A (if no, see Instructions)

Casualty/property insurance? Yes No

If yes, are your premiums current? Yes No N/A (if no, see Instructions)

General liability insurance? Yes No

If yes, are your premiums current? Yes No N/A (if no, see Instructions)

j. Has a plan of reorganization been filed with the court? Yes No

k. Has a disclosure statement been filed with the court? Yes No

l. Are you current with quarterly U.S. Trustee fees as 

set forth under 28 U.S.C. § 1930?

Yes No

Case 21-13797-SMG Doc 682 Filed 05/24/22 Page 8 of 12
UST Form 11-MOR (12/01/2021) 9

Debtor's Name LIBERTY POWER HOLDINGS, LLC, 

LPT, LLC, 

Case No. 21-13797

Part 8: Individual Chapter 11 Debtors (Only)

a. Gross income (receipts) from salary and wages $0

b. Gross income (receipts) from self-employment $0

c. Gross income from all other sources $0

d. Total income in the reporting period (a+b+c) $0

e. Payroll deductions $0

f. Self-employment related expenses $0

g. Living expenses $0

h. All other expenses $0

i. Total expenses in the reporting period (e+f+g+h) $0

j. Difference between total income and total expenses (d-i) $0

k. List the total amount of all postpetition debts that are past due $0

l. Are you required to pay any Domestic Support Obligations as defined by 11 

U.S.C § 101(14A)?

Yes No

m. If yes, have you made all Domestic Support Obligation payments? Yes No N/A

Privacy Act Statement 

28 U.S.C. § 589b authorizes the collection of this information, and provision of this information is mandatory under 11 U.S.C. 

§§ 704, 1106, and 1107. The United States Trustee will use this information to calculate statutory fee assessments under 28 

U.S.C. § 1930(a)(6). The United States Trustee will also use this information to evaluate a chapter 11 debtor's progress 

through the bankruptcy system, including the likelihood of a plan of reorganization being confirmed and whether the case is 

being prosecuted in good faith. This information may be disclosed to a bankruptcy trustee or examiner when the information 

is needed to perform the trustee's or examiner's duties or to the appropriate federal, state, local, regulatory, tribal, or foreign 

law enforcement agency when the information indicates a violation or potential violation of law. Other disclosures may be 

made for routine purposes. For a discussion of the types of routine disclosures that may be made, you may consult the 

Executive Office for United States Trustee's systems of records notice, UST-001, "Bankruptcy Case Files and Associated 

Records." See 71 Fed. Reg. 59,818 et seq. (Oct. 11, 2006). A copy of the notice may be obtained at the following link: http://

www.justice.gov/ust/eo/rules_regulations/index.htm. Failure to provide this information could result in the dismissal or 

conversion of your bankruptcy case or other action by the United States Trustee. 11 U.S.C. § 1112(b)(4)(F). 

I declare under penalty of perjury that the foregoing Monthly Operating Report and its supporting 

documentation are true and correct and that I have been authorized to sign this report on behalf of the 

estate.

/s/ Victoria M. Dusch

Signature of Responsible Party

Chief Financial Officer

Printed Name of Responsible Party

05/17/2022

Title Date

Victoria M. Dusch

Case 21-13797-SMG Doc 682 Filed 05/24/22 Page 9 of 12
UST Form 11-MOR (12/01/2021) 10

Debtor's Name LIBERTY POWER HOLDINGS, LLC, 

LPT, LLC, 

Case No. 21-13797

PageOnePartOne

PageOnePartTwo

PageTwoPartOne

PageTwoPartTwo

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UST Form 11-MOR (12/01/2021) 11

Debtor's Name LIBERTY POWER HOLDINGS, LLC, 

LPT, LLC, 

Case No. 21-13797

Bankruptcy51to100

NonBankruptcy1to50

NonBankruptcy51to100

Bankruptcy1to50

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UST Form 11-MOR (12/01/2021) 12

Debtor's Name LIBERTY POWER HOLDINGS, LLC, 

LPT, LLC, 

Case No. 21-13797

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PageThree

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