UNITED STATES BANKRUPTCY COURT

SOUTHERN DISTRICT OF FLORIDA 

WEST PALM BEACH DIVISION 

www.flsb.uscourts.gov

IN RE: CASE NO.: 22-12790-EPK

EXCELL AUTO GROUP, INC., Chapter 7

CHRISTOPHER TODD BLUDWORTH AND ANDREW TODD McNEILL’S

MOTION TO COMPEL TRUSTEE TO TURN OVER NON-ESTATE

PROPERTY, 2021 MOKE VEHICLE

Christopher Todd Bludworth and Andrew Todd McNeill (collectively, the

“Owners/Parties-in-Interest”). move for entry of an Order directing the Trustee, Nicole Testa

Mehdipour (the “Trustee”), to turn over the Owners/Parties-in-Interest’s 2021 Moke, VIN 

4C9WAHBG0MS092505 (the “Moke”), which does not constitute property of the estate. In

support ofthe Motion, the Owners/Parties-in-Interest state:

Background1

1. On April 8, 2022 (the “Petition Date”). Excell Auto Group, Inc. (the “Debtor”)

filed a Voluntary Petition for relief under Chapter 7 ofthe Bankruptcy Code.

2. The Trustee is the duly appointed and acting Chapter 7 Trustee of the Debtor’s

estate.

3. On November 15, 2021, the Owners/Parties-in-Interest purchased the Moke from

third-parties, Vicky Keith and Madeliene Abling.

1 Attached hereto as Exhibit “1” is the Affidavit ofChristopher Todd Blndworth in Support of

Christopher Todd Blndworth and Andrew Todd McNeill's Motion to Compel Turnover ofNonEstate Property, 2021 Moke (one ofthe owners ofthe Moke), attesting to the facts stated herein.

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Case 22-12790-EPK Doc 121 Filed 05/27/22 Page 1 of 28
4. In December 2021, the Owners/Parties-in-Interest noticed that the front right tire 

was wearing and they inquired of the previous owners in mid-December 2021, if they had

information on the warranty or knew of a certified Moke mechanic in the area to service the

Moke. The previous owners advised that they were not aware of a mechanic in the area who

services Mokes.

5. On March 26, 2022, while driving the Moke, the Owners/Parties-in-Interest 

noticed a rubbing sound that the Owners/Parties-in-Interest assumed may have something to do

with the previously noticed wearing of the front right tire, and passed by a golf cart shop,

Beachside Golf Cars (“Beachside”) located at 317 N. Federal Highway, Fort Lauderdale, FL

33301. The Owners/Parties-in-Interest called Beachside on the same day (March 26, 2022) to

inquire if Beachside could service and repair the Moke. Having been advised by the Beachside 

representative that Beachside does not service Mokes at this time, Beachside referred the

Owners/Parties-in-Interest to an independent mechanic and a certified mechanic named Melton 

to make repairs to the Moke.

6. On the same day (March 26, 2022), the Owners/Parties-in-Interest called Melton,

who confirmed that he was certified to perform service on Mokes and who also confirmed that 

he could transport the Moke on a trailer from the Owners/Parties-in-Interest’s home in Fort 

Lauderdale, Florida, in order to have the front tires replaced, an alignment done, and the batteries 

checked (collectively, the “Service and Repairs”).

7. On April 5, 2022 at approximately 3:00 p.m., the Moke was picked up for service

from the home of the Owners-Parties-in-Interest by someone with a trailer, sent by Melton, for 

the Service and Repairs.

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Case 22-12790-EPK Doc 121 Filed 05/27/22 Page 2 of 28
8. On April 8, 2022, the Owners/Parties-in-Interest called Melton to inquire as to the

status ofthe Service and Repairs and to request an estimate for same. Melton indicated that he

was finishing other vehicles and would get to the Service and Repairs for the Moke over the

weekend of April 9-10, 2022. The Owners/Parties-in-Interest informed Melton that there was no

rush as the Owners/Parties-in-Interest were taking their family to New York for Spring Break 

and that they would be returning from their vacation around April 19, 2022.

9. On Monday, April 11, 2022, at 7:42 p.m., the Owners/Parties-in-Interest received 

a telephone call from Melton while they were in New York. Melton advised the Owners/Partiesin-Interest that the Moke had been confiscated, that there was some lawsuit that had been filed

(which the Owners/Parties-in-Interest now believe was the commencement of this bankruptcy

case) and to come the next day at 12:30 p.m. with the title and vehicle registration for the Moke,

so that the Owners/Parties-in-Interest could retrieve the Moke. Melton also provided the

Owners/Parties-in-Interest with a telephone number for the Trustee.

10. On April 11, 2022, Mr. Bludworth and the Trustee corresponded by electronic 

mail with respect to the Moke and the Trustee advised that the Moke is at the Debtor’s premises.

On or about April 23, 2022, through a subsequent e-mail between Mr. Bludworth and the

Trustee, Mr. Bludworth was advised that the Moke was on a showroom floor at the Debtor’s

premises.

11. On May 17, 2022, special counsel for the Trustee corresponded with Mr.

Bludworth advising that the Moke came into either the possession of the Debtor or non-debtor,

Karma of Palm Beach, and confirmed that the Moke was placed on the showroom floor, as it was

believed that the Moke had come to the Debtor on consignment.

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Case 22-12790-EPK Doc 121 Filed 05/27/22 Page 3 of 28
Relief Requested

12. By this Motion, at the request of Trustee’s counsel, the Owners/Parties-in-Interest 

request turnover ofthe Moke because it is not owned by the Debtor. The Moke was not brought 

to the Debtor on consignment. The Moke was picked up from the home ofthe Owners/Partiesin-Interest on April 5, 2022 (three days prior to the Petition Date) solely for performance of the 

Service and Repairs identified above by Melton, with no notice that he was an employee of any

third party, including the Debtor.

13. The Owners/Parties-in-Interest were advised by Beachside to contact Melton, an

independent mechanic and certified Moke mechanic, to facilitate the Service and Repairs.

Again, at no time were the Owners/Parties-in-Interest advised that Melton was an employee of

the Debtor. Regardless, the Owners/Parties-in-Interest are the rightful and sole owners of the

Moke, which is not subject to any liens or encumbrances by any third parties, including the

Debtor which, upon information and belief, has performed none ofthe Service and Repairs. In

short, the Moke is not property of the Debtor’s estate under 11 U.S.C. § 541(a) and, therefore, 

should be turned over to the Owners/Parties-in-Interest.

14. The Trustee’s counsel has advised that the Trustee has no objection to the relief

sought in this Motion and to turning over the Moke to the Owners/Parties-in-Interest, but 

requires an order ofthis Court directing her to do so. Hence, the filing ofthis Motion.

15. In addition, counsel for secured creditor, Auto Wholesale of Boca, Inc., has

advised the undersigned that Auto Wholesale of Boca, Inc. has no objection to the relief

requested in this Motion.

WHEREFORE, Owners/Parties-in-Interest respectfully request the entry of an Order in

the form attached hereto as Exhibit “2” (i) granting this Motion; (ii) directing the Trustee to turn

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Case 22-12790-EPK Doc 121 Filed 05/27/22 Page 4 of 28
over the Moke to the Owners/Parties-in-Interest; and (iii) granting such other and further relief as

the Court deemsjust and proper.

Dated: May 27, 2022.

Respectfully submitted,

BERGER SINGERMAN LLP

Counsel for Creditors

201 E. Las Olas Boulevard, Suite 1500

Fort Lauderdale, FL 33301

Tel. (954) 525-9900

Fax (954) 523-2872

By: /s/ PaidA. Avron_____________

Paul A. Avron

Florida Bar No. 50814

mvron@bergersingerman.com

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a true and correct copy of the foregoing was served on the

27th day of May, 2022, via (i) electronic transmission through the bourt’s CM/Ebb system upon

all parties on the attached CM/ECF Service List, and (ii) first class, U.S. Mail to Karma of Palm

Beach, Attn.: Scott Zankl, President, 1001 Clint Moore Road, Suite 103, Boca Raton, FL 33487.

By: /s/ PaidA. Avron

Paul A. Avron

5

Case 22-12790-EPK Doc 121 Filed 05/27/22 Page 5 of 28
CM/ECF SERVICE LIST

• Joaquin J Alemany joaquin.alemany@hklaw.com, jose.casal@hklaw.com

• Zachary J Bancroft zbancroft@bakerdonelson.com,

sdenny@bakerdonelson.com,bkcts@bakerdonelson.com

• Eyal Berger eyal.berger@akerman.com, jeanette.martinezgoldberg@akerman.com

• Stephen C Breuer stephen@breuer.law,

genna@breuer.law,stephen@ecf.courtdrive.com

• Alan R Crane acrane@furrcohen.com,

rrivera@furrcohen. com; ltitus@furrcohen. com;staff1 @furrcohen.com

• Mitchell A Dinkin mdinkin@madlegal.net, lucyd@madlegal.net

• Dana L Kaplan dana@kelleylawoffice.com,

cassandra@kelleylawoffice.com;debbie@kelleylawoffice.com;craig@kelleylawoffice.co

m;kelleycr75945@notify.bestcase.com;scott@kelleylawoffice.com

• Mark A Levy mark.levy@brinkleymorgan.com,

sandra.gonzalez@brinkleymorgan.com;brinkleymorganecf@gmail.com

• James Randolph Liebler jrlii@lgplaw.com, mkv@lgplaw.com

• Nathan G Mancuso ngm@mancuso-law.com

• David B Marks brett.marks@akerman.com, charlene.cerda@akerman.com

• Nicole Testa Mehdipour nicolem@ntmlawfirm.com,

cm_ecf_service@ntmlawfirm.com;atty_mehdipour@bluestylus.com;cmecfservice@gmai

l.com;mehdipoumr85783@notify.bestcase.com

• Nicole Testa Mehdipour Trustee@ntmlawfirm.com,

TRUSTEE_CMECF_Service@ntmlawfirm.com;FL80@ecfcbis.com;ntm@trustesolution 

s.net;BCasey@ntmlawfirm. com

• James B Miller bkcmiami@gmail.com

• James C. Moon jmoon@melandbudwick.com,

ltannenbaum@melandbudwick.com;mrbnefs@yahoo.com;jmoon@ecf.courtdrive.com;lta 

nnenbaum@ecf. courtdrive. com;phomia@ecf. courtdrive. com

• Office ofthe US Trustee USTPRegion21.MM.ECF@usdoj.gov

• John E Page jpage@slp.law,

dwoodall@slp.law;pmouton@slp.law;pmouton@ecf.courtdrive.com;jpage@ecf.courtdriv

e.com

• Eric S Pendergraft ependergraft@slp.law,

dwoodall@slp.law;dlocascio@slp.law;bshraibergecfmail@gmail.com;pmouton@slp.law

• Hampton Peterson legalservices@PBCTax.com

• Jordan L Rappaport office@rorlawfirm.com, 1678370420@filings.docketbird.com

• David A Ray dray@draypa.com,

sramirez.dar@gmail. com,cm_ecf_service@ntmlawfirm. com

• Ivan J Reich ireich@nasonyeager.com, msmith@nasonyeager.com

• Jason S Rigoli jrigoli@furrcohen.com, rrivera@furrcohen.com;staffl@furrcohen.com

• Harry J Ross hross@hjrlaw.com, jerri@hjrlaw.com

• JohnD. Segaul john@segaul.com,

court@segaulstoll.com;melissa@segaul.com;segaullawfirmpa@jubileebk.net

• ZachB Shelomith zbs@lss.law, info@lss.law;zshelomith@ecf.inforuptcy.com

6

Case 22-12790-EPK Doc 121 Filed 05/27/22 Page 6 of 28
• Bradley S Shraiberg bss@slp.law,

dwoodall@slp.law;dwoodall@ecf.courtdrive.com;pmouton@sip.law

• Eric J Silver esilver@steamsweaver.com,

jless@steamsweaver.com;fsanchez@stearnsweaver.com;cgraver@steamsweaver.com;mf

ernandez@stearnsweaver.com

• David R. Softness david@softnesslaw.com

• Peter D Spindel peterspindel@gmail.com, peterspindelcmecf@gmail.com

• Mark E Steiner MES@lgplaw.com, pm@lgplaw.com

• Aaron A Wernick awernick@wemicklaw.com,

awernick@ecf.courtdrive.com;crubin@wemicklaw.com;dkariotis@wemicklaw.com;mla 

verriere@wemicklaw. com

• Paul E Wilson pwilson@paulwilsonesq.com

• Harry Winderman harry4334@hotmail.com,

lynoramae@gmail.com,lm@whcfla.com,filings@whcfla.com

• Thomas G Zeichman tzeichman@bmulaw.com, G67999@notify.cincompass.com

7

Case 22-12790-EPK Doc 121 Filed 05/27/22 Page 7 of 28
EXHIBIT “1”

Case 22-12790-EPK Doc 121 Filed 05/27/22 Page 8 of 28
UNITED STATES BANKRUPTCY COURT

SOUTHERN DISTRICT OF FLORIDA

WEST PALM BEACH DIVISION

www.flsb.iiscourts.gov

IN RE: CASE NO.: 22-12790-EPK

EXCELL AUTO GROUP, INC., Chapter 7

Debtor.

______________________________________________ /

AFFIDAVIT OF CHRISTOPHER TODD BLUDWORTH IN SUPPORT OF

CHRISTOPHER TODD BLUDWORTH AND ANDREW TODD

McNEILL’S MOTION TO COMPEL TRUSTEE TO TURN OVER OF

NON-ESTATE PROPERTY, 2021 MOKE

STATE OF FLORIDA 

COUNTY OF BROWARD

1. My name is Christopher Todd Bludworth and I am over eighteen years of age.

2. I make this Affidavit based upon my personal knowledge, and in support of

Christopher ToddBludworth andAndrew ToddMcNeill’s Motion to Compel Trustee to Turn Over

Non-Estate Property, 2021 Moke (the “Motion”).

3. On November 15, 2021, I, together with husband, Andrew Todd McNeill, 

purchased a baby blue colored 2021 Moke, bearing YIN 4C9WAHBG0MS092505 (the “Moke”)

from the original owners, Vicky Keith and Madeliene Abling. The Moke was originally purchased 

from Orlando Infinite by Vicky Keith and Madeliene Abling on February 16, 2021. No other

parties have had possession ofthe Moke. See (i) Buyer’s Order, Agreement & Vehicle Information

Form dated Febmary 16,2021, evidencing that Vicky Keith and Madeliene Abiling purchased the

vehicle from Orlando Infinite; (ii) Certificate ofTitle issued onMay 4,2021, evidencing thatVicky

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Case 22-12790-EPK Doc 121 Filed 05/27/22 Page 9 of 28
Keith and Madeliene Abling were the registered owners of the Moke; and (iii) Notice ofSale

and/or Bill of Sale for a Motor Vehicle, Mobile Home, Off-Highway Vehicle or Vessel dated

November 15, 2021, evidencing that the Moke was purchased by me and my husband from Vicky

Keith and Madeliene Abling on November 15, 2021, attached hereto as Composite Exhibit “A”.

4. The Moke is titled and insured in both my name and my husband’s name and is

also registered in the State of Florida under both my name and my husband’s name. See (i)

Certificate of Title issued on November 15, 2021, (ii) USAA Casualty Insurance Company

insurance card; and (iii) Florida Vehicle Registration issued on November 15, 2021, attached 

hereto as Composite Exhibit “B”.

5. In December 2021, my husband and I noticed that the front right tire was wearing 

and had asked the previous owners, Vicky Keith and Medeliene Albing, in mid-December 2021,

ifthey had information on the warranty or knew ofa certified Moke mechanic in the area to service 

the Moke. My husband and I were unsuccessful in finding a certified Moke mechanic at that time.

6. On Saturday, March 26, 2022, my husband and I were driving the Moke with our 

children and noticed a rubbing sound. We assumed it may also have something to do with the

previously noticed wearing ofthe front right tire. We passed by a golf cart shop, Beachside Golf

Cars (‘"Beachside”), located at 317 N. Federal Highway, Fort Lauderdale, FL 33301, and called

the phone number on their signage (754-206-2203). We called at 3:21 p.m. on the same day, 

March 26, 2022, to inquire if they could service and repair the Moke. The representative of

Beachside Golf Cars indicated that they do not service Mokes at this time but referred us to an

individual named Melton, an independent mechanic and certified Moke mechanic, to make repairs 

to our Moke. My husband and I were provided a telephone number to contact Melton.

11422412-3

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Case 22-12790-EPK Doc 121 Filed 05/27/22 Page 10 of 28
7. That same day, on Saturday, March 26, 2022, we called Melton at 2:35 p.m. who

confirmed that he was certified to service Mokes. Melton confirmed that he could transport the

Moke on a trailer from our home to his garage for service.

8. On April 5, 2022, at approximately 3:00 p.m., the Moke was picked up for service 

by someone with a trailer, sent by Melton, at my home, in order to have the front tired replaced, 

an alignment done, and the batteries checked (the “Service and Repairs”).

9. On Friday, April 8, 2022,1 called Melton at 4:06 p.m. asking him for an update on 

the Moke, and asked ifhe had an estimate for the repairs. Melton said that he was finishing other 

vehicles and would get to our vehicle over the weekend of April 9-10, 2022. I informed Melton 

that there was no rush as my husband and I were taking our children to New York for their Spring 

Break and returning around April 19, 2022.

10. On Monday, April 11,2022, at 7:42 p.m., we received a call from Melton while we

were in New York. Melton said our Moke had been “confiscated.” Melton said there was some

sort oflawsuit and to come the next day at 12:30 p m, with the title and vehicle registration for our 

Moke, and we could retrieve the Moke. This is the first we had ever heard ofthe company Excell 

Auto Group, Inc. (“Excel!” or the “Debtor”) and ofthe Chapter 7 bankruptcy filing by the Debtor.

Melton told us what little he knew and gave us a telephone phone number for Nicole Mehdipour, 

who I understand is the Chapter 7 Trustee (the “Trustee”) for the Debtor’s bankruptcy estate.

11. My husband and I called and texted the Trustee immediately (See text messages 

attached hereto as Exhibit “C”) starting on April 11,2022. Since that time, I have been attempting 

to communicate, through electronic mail, directly with the Trustee and her special counsel, Alan 

Crane, Esq. ofFurr and Cohen, P.A., in order to arrange for the pick-up ofthe Moke.

11422412-3

3

Case 22-12790-EPK Doc 121 Filed 05/27/22 Page 11 of 28
12. After the first text with the Trustee, the Trustee said to send her a picture ofthe

Moke, our registration and title, which we did immediately. The Trustee told us to let her know

when we were back in town. Upon returning to Fort Lauderdale, we attempted to reach the

Trustee several times by telephone and text messages, with no response.

13. During these communications, I was advised that the Moke was located on the

showroom floor and that the Debtor believed that the Moke had come to the Debtor on

consignment. At no point was the Moke there on consignment. This is a new purchase for our

family and we had no intention ofselling it.

14. At no time did I or my husband intend or approve for the Moke to be on

consignment. The Moke was picked up on April 5, 2022, for the sole pmpose ofhaving the front 

tires changed and an alignment by the independent mechanic, Melton, to perform the Service and

Repairs, not as an employee of any third party, including Excell.

15. In fact, prior to April 11,2022, neither I nor my husband ever heard ofExcell. We

still retain the charger, extra key and all paperwork establishing our ownership of the Moke 

because it was to be returned to us after the Service and Repairs.

16. Upon information and belief, the Services and Repairs have not been undertaken 

by Melton, individually, or on behalf ofExcell.

17. My husband and I are the rightful owners ofthe Moke.

18. Excell has no ownership interest in the Moke.

i

'

11422412-3

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Case 22-12790-EPK Doc 121 Filed 05/27/22 Page 12 of 28
19. The Moke is not subject to any liens or encumbrances.

FURTHER AFFIANT SAYETH NAUGHT.

STATE OF FLORIDA

COUNTY OF BROWARD

The foregoing instrument was acknowledged before me by means of ^physical presence 

or □ online notarization, this dS day of May, 2022, by CHRISTOPHER TODD

BLUDWORTH who is personally known to me or who has produced___________ _ as

identification.

My Comm. Expires

04-14-2024

No. QG 978402

Notaiy Public, State ofFlorida^

My Commission Expires: A. ~ ^-0^4

;

i;

i]

i

11422412-3

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Case 22-12790-EPK Doc 121 Filed 05/27/22 Page 13 of 28
COMPOSITE EXHIBIT “A”

Case 22-12790-EPK Doc 121 Filed 05/27/22 Page 14 of 28
ORLAN0Q

Buyers Order» Agreement

^Vehicle information Form

4237 Miltenia Bivd. * Criando, FL 32839 

(407) 660-0077 • Fa;.: (407) 660-2647

74 OUSTS: 223311

Co-Buyer Name and Address

MADELINE ABLING

Buyer Name and Address

Seller Name and Address

VICKY KEITH

ORLANDO INFINITI

4237 MJLLENIA BLVO

£0unti&RO«ARO ORLANDO FL 32839

Email:

County: BROWARD

Email:

Phone;

_________________________________ ___ Cell. ______ _____ _

In this Buyer s Order, Agreement and Vehicle Information,Form f

. Order and Agreement”), “you" means the buyer, and

us” and “our” means the Selier, Ybu agree to purchase the vehicle tram us according to the

Mode! Mileage:

Stock dumber;

!*0f23*

any co-buyer,

terms of this Order and Agreement.

Make:

New/Used/Demo/Executive:

Vehicle Description

MFW

Vehicle Identification Number:

BLUE ____ j_ LOW" _r: _

Additional Vehicle Information

Unless checked below. Seller has no knowledgcTo/ana1ZJ THIS VEHICLE WAS DELiVEBhD TO A PREVIOUS PURCHASER.'

Buyer X ■■_________________i . t aa__________ ll_________________ : makes no representation about the history of the

vehicle.

The vehicle was previously titled, registered, or used

as a (check as applicable) □taxicab □ police vehicle

□ shortterm rental.

The vehicle is (check as applicable) □ rebuiil or

assembled from parts □ a kit car □ a glider kit

□ a replica □ a flood vehicle'□ a manufacturer buy

back.

Co-Buyer X

Purchase Information (e) means an estimate

Disclosures

Unless the Seller makes makes a written

warranty, or enters Into a service contract

within 90 days from the date of this

contract, this vehicle is sold 'AS IS” and

‘WITH ALL FAULTS ” The Seller makes no

warranties, express or implied, on the

vehicle, and there will be no implied 

warranties of merchantability or of fitness

for a particular purpose.

This provision does not affect any warranties covering

Ihe vehicle that the vehicle manufacturer may provide.

Buyer acknowledges receipt of any warranty

information prior to the sale of the vehicle.

Buyer’s Initials Co-Buyer's Initials ^

Used Car Buyers Guide. The information you

see on the window form for this vehicle is part

of this contract. Information on the window

form overrides any contrary provisions in the

contract of sale.

Spanish Translation: Guta para compradores

de vehfeiilos usados. La informacidrs pue veen ei formulario de fa ventaoifla para eslf creditor Lea® Balance

vehfculo forma parte de! presente comrato. «.a

informacion del formulario de la ventanilia

deja sin efecto toaa disposicidn en contragio

contenida en el contrato de venta.

You have thoroughly inspected, accaple-cL and

approved the vehicle described above in ah

respects. You may obtain an independent third

party inspection of the vehicle on yctir own.

Buyer’s Initials Co-Buyer’s Initials

We acknowledge that as a condition of sale of the

Vehicle, we will perform the following services within

-----------' days Ol the dale ot purchase. Call

___ .. ........ ........ tu schedule servico.

Vehicle Purchase Price

Accessories

Subtotal

Lass Allowance or Discount of

Net: Difference

Predelivery Service charge'*'

electronic RegistTotion Filing Fee

"These charges represent costs and profit to the

dealer for items such as Inspecting, .cleaning, and

adjusting vehicles, andpreparing documents related

to the sale.

Lead Acid Battery Fee

Mew Tire Fee (S1.00 per tire)

Subtotal

Sales Tax

County Tax

Other Tax

Lemon Law Warranty Enforcement Act .n^c^s

Title, Registration, and License Fees (e)

.□ New □transfer __________

Subtotal

Service Contract

i Maintenance Aqre&mant

Sales Tax on Ancillary Products

Total Sale Price

Rebate

Oth^r L>ownpdymon£ (l->escrir»«)

total Downpaymem

Case 22-12790-EPK Doc 121 Filed 05/27/22 Page 15 of 28
■Ul >!■ uwei ■ tut

contract of sale.

ty owniraiy provisions in the cement Act rwc8r.

I Spanish Translation: Gufa para compradoras rn k'i Re9j^r^tlon' and LlCense Fees (e)

de vehiculos usados. La informacion que ve Nevv ■—* TranstgL

en el formulario de la ventanilla para este------ -------------------------------------

veh/culo forma parte del presente contrato. La ! Prior Credit or Lease Balance

Informacion del formulario de la ventanilla

deja sin efecto toda disposicion en eomrerio

conten/da^en el contrato de venta.

You have thoroughly inspected, accepted, and

I approved the vehicle described above (n all l—

respects. You may obtain an independent third -

party inspection of the vehicle on your own.

Buyer's Initials _______ Co-Buyer’s Initials

Subtotal

Service Contract

We acknowledge that as a condition of sale of the

VWVcto, Lve wUi perform tho following services within

_1___ ___ days of the date of purchase. Call

_______________ ______ to schedule service.

Trade-in Vehicle , Trade-in Vehicle

Year________ _ Make ’ Model Yoar Make Model

VIN . . ^ Mileage VfM Mileage

Lienholder Lienholder

Payoff Amount fTnori Thru: Payoff Amount Good Thru: _

Lienholder Lienholder. , - . .

Payoff Amount Good Thru: ' Payoff Amount - Good Thru: ............ .

You assign to us all of your rights, title and interest In such T

was not previously used as apollce vehicle, taxicab, or under a

you are trading in L] have [J have not been in any accident v

Buyer Initials Co-Buyer Initials .

rade-in vehtcle(s). You represent that your Trade-in vehicle(s)

Short-term lease. To the best of your knowledge, the vehicle(s)

yith damages exceeding $500.

i

- ■' • ' - !

OCLLcn o nlun I I u OMrtonL - u cuyer ana vo-ouyersign nere, tne provisiuns ui me oviivt s» ruym iv vaiivci sc-uun uu uia t-a-r, w«mbn

gives the Seller the right to cancel if Seller is unable to assign a Retail Installment Sale Contract signedvvith this Order and Agreement

within '• . days, will apply. If you fail to return the vehicle within 4p hoursafterreceipt of the notice of cancellation, you agree

to pay Seller a Charge of S ______________ per day from the date of cancelation until the vehicle is'returned or repossessed.

50.00

Buyer Signs Co-Buyer Signs x:

,,t(s) quoted is/are an--------------------a—

vei liclefs^, or a designee. If the actual payoff amount(s) isteremore than-------------------------------------,-

is less than the amount(s) shown above, we will refund to you any overage we receive from your prior [s) or lessor®.

f amount(s) shown aboveYou

1) or lessor(s) of the Trade-in

f the actual payoff amount(s)

la ie6S iridfl Ultt dlllUUIlllo) ailimil auuvp, ram iciui m iu yuu ....... ,—------------- _____________________________________ ______________________________

You may secure financing through us or through any financing entity you choose.The financing terms you get could be more

favorable than the terms we give you. If we sell you any ancillary product, such as credit insurance or GAP, we may receive

part of the cost of the product and/or other compensation from m provider of the product.___________ ■ _

Percentage Rate io.

Sale Contract to a fi

Section 501.98, Florida Statutes, requires that, at least 30 days before bringing any claim against a motor vehicle dealar lor an unfair or

deceptive trade practice, a consumer must provide the dealer with a written demand letter stating the name, address, and telephone , number ofthe consumer; the name and address ofthe dealer; a description ofthe facts that serve as the basis ipr the claim; the amount i

of damages- and copies of any documents in the possession of the consumer which relate to theclaim. Such notice must be deliveredby,

the United States Postal Service or by a nationally recognized carrier, return receipt requested, to the address where tne subject vehicle i

was purchased or leased or where the subject transaction ciccufred. pran address at which the dealer regularly conducts business.

x - 1

Co-Buyer’s Signature

O^ranSbSkarSmentTepresents thefinal agreementbetweeo the partly rela^dtp the sale of tt^ vehicle and may

/■riot be contramotSd oyfevidence of prior, contemporaneous,or subsequent oral agreements of theparties.

a„wor Qionc- Y ' * ,. ■ ■ _ i_____ ------------------------ Co-Buyer Signs-fX-----------------------------MM------------------------------ YouehaSJInread each page of this Order and Agreement,jncluding'the arbitration provision on the reverse side, and agree

to its terms/Ydfijiave received a completely filled in copy of this.Order.'and Agreement. > ^ ^

Buyer Signs: X ^ ^ v , v _ , , . .

Accepted Si - ----- ———----------------------------------------- ^

\LMN TrlE IWOEHUAKISSOVMSIUjrr.-. UVHfcCSOR

nwe» FWtPUBPOStW IMIS FOAM CO^-UIT LEOA. J:

___ Co:Buyer Signs! X _

CC736122 0 ,<*«)

Case 22-12790-EPK Doc 121 Filed 05/27/22 Page 16 of 28
Mail Lien Satisfaction to: Dept of Highway Safety and Motor Vehicles, Neil Kirtman BuBding, Tallahassee. FL 3239a-tI5ao

Idenllfication Number -------------------- Year — Make - Body r~ WT-L-BHP — Vessel Regis. No.

14C9WAHBG0MS092505 2021 MOKE. GC 22(XL

Tile Number —

142507325

Registered Owner:

VICKY LEE KEITH OR

MADELIENE CAROL ABLH

Date of Issue 05/04/2021

Mail To:

VICKY LEE KEITH

Lien Release

Interest in the described vehicle Is hereby released

By________________________________________

Title______ _____________

Date______________________________

IMPORTANT INFORMATION

1. When ownership of the vehicle described herein is

transferred, ihe selierMUST complete in full the

Transfarof Tille by Seller section at the bottom of

the certificate of tills.

2. Upon sale of this vehicle, the seller must complete

the notice of sale on the reverse side of this form.

3. Remove your license plate from the vehicle.

4. Sea the web address below for more information and

the appropriate forms required forthe purchaser to 

title and register the vehicle, mobile home orvessel:

htlpJA-ww.flhsmv.gov/html/titlinf.html

;murr.v5ikckuciwrint

.ktentlflealten Number Vessel Regis. Nc

Primary Brand Secondary Brand Prey Issue Dale -

PRIVATE

- Dale Of Issue “

05/04/2021

Odometer Satus or Vessel Manufacturer or OH use

7 MILES 02/18/2021 ACTUAL

Registered Owner

VICKY LEE KEITH OR

MADELIENE CAROL ABLING

1 stLienholder

NONE

FLORIDA DEPARTMENT OF HIGHWAY SAFETY AND MOTOR VEHICLES DIVISION OF MOTORIST SERVICES

Control Number

Terry L. Rhodes

Executive Director Rohert R. Kynoch

Director

------------------ TRANSFER OF TITLE BY SELLER (This section must be completed at Ihe lime of sale.) —--------------

Federal aniL'nr nUnte law require ihnl the idler Muir Ihe milese. purdiww'n name, aellin^price tend dale sold in conneelinn with the Cmnsdo- ot'nwncc&hip.

Failure la complete orproviding a faisc :iu!enicnt may reuull in fines iind/orimprisonment.

Uns any liens eycepl ns noted on the face ofihe certificate and the nmlnr vehicle or vessel described is hereby tnmsfoTe iiilc is

Addrttnr

Seller Mum Killer 13ale Sold: / t

ItfJII^IJ 2;il£||3| | x ((no inntlui) inilra, tide read and ttierehy eertlfy Ihaliotheheal ofmy knowledRe ihe odometer reading:

IE. □ 1. isINKXCESS OK ITS MECHANIC At. UKtTI-S. [^j 3. UNOTTHEACmiAI.Mir.KAOE.

IE THAT I HAVE READ THE FOREGOING DOCUMENT AND THAT THE FACTS STATED IN IT ARE TRUE.

^ CO-SEIXKR Filust ,/?_ /

f\ Sipi Here: 1 ' —_l '—__— \ -----

Prinl Here: fSlAD ___ _________

Selling Deoltt's LicenseNnmhtr:

Aodion Name

CO-PURCHASER Mnni

Sigh <

Print Here: %

PURCHASER Mtut

Sign. Here: jfC.

Prinl Here:

irjirinfcuiii

11ITI

IITirl

1H

hmm

Case 22-12790-EPK Doc 121 Filed 05/27/22 Page 17 of 28
STATI OF FLORIDA

DEPARTMENT OF HIGHWAY SAFETY AND MOTOR VEHICLES - DIVISION OF MOTORIST SERVICES

SIBMTTHS KX^TOYXRIXX^IAXOOtlKnaiOraCI

WWWBhsnw.aav offices/

Notice of Sale and/or Bill of Sale for a Motor Vehicle,

Mobile Home, Off-Highway Vehicle or Vessel

□ Notice of Sale (Seller must complete sections 1 & 3). The purchaser’s si

D Bill of Sale (Seller and purchaser must complete sections 1. 2 (when applicable^ & 3V

gnature in section 3 is optional.

1.

Y*»r

Motor Vehicle, Mobile Home, Off- Highway orVessel Description

202J

Make/Manufacturw

C*ftJflcat» of TWO Numbor

I IzTO^lz.Z'

MoKe

Body Typ«

recurrent Title luue Data

))- 1

Model Color

Glut

Identification Numbflf

S 092 5*^5“

l/we do hereby sell or have sold and delivered the above described motor vehicle, mobile home,

off-highway vehicle or vessel to:_________ ________________•

Print of viPurchaser!*) rurviiAKTl»; .a a

thmiepter TM gtod mth yJ /Mrew Ttdff 11

Address Zip Code

Date ofSale

fllwwlwt 15,2011

2. Odometer Disclosure Statement (Required For a Motor Vehicle)

Federal and State law requires that you state the mileage in connection with the transfer of ownership. Failure to

complete or providing a false statement may resultIn fines and/or imprisonment

WE STATE THAT THIS MOTOR VEHICLE'S □5 DIGIT OR | I 6 DIGIT ODOMETER NOW READS I 11 11 L fz][?] Ps].n

(NO TENTHS) MILES. DATE READ /* / / ^ / . AND WE HEREBY CERTIFY THAT TO THE BEST OF OUR KNOWLEDGE

THE ODOMETER READING:

U1. REFLECTS THE ACTUAL MILEAGE. Q 2. IS IN EXCESS OF ITS MECHANICAL LIMITS. Q S. IS NOTTHEACTUAL MILEAGE

Affidavit (When applicable);

3. Certification

UNDER PENALTIES OF PERJURY, I DECLARE THAT I HAVE READ THE FOREGOING DOCUMENT AND THATTHE FACTS

STATED IN ITARETRUE

Seller's Signature

SeUftf's Address

UjCtu fei-fr

"city 7

Date

tthffZozl

State Zip Code

* OWNERSHIP STATUS FOR THE ABOVE DESCRIBED MOTOR VEHICLE, MOBILE HOME, OFF-HIGHWAY VEHICLE OR VESSEL

WILL NOT CHANGE UNTIL THE PURCHASER APPUES FOR AND IS ISSUED A CERTIFICATE OF TITLE

Q*xk ysx kxaJ ptare book gmcmnrrtf pages or visii the fcfavwng v,cbsitt fcr aircni maing addresses: tap:/ / wv^lhsmv.govf1 ofoes/

HSMV 62050 (Rev. 03/21) S

Case 22-12790-EPK Doc 121 Filed 05/27/22 Page 18 of 28
COMPOSITE EXHIBIT “B”

Case 22-12790-EPK Doc 121 Filed 05/27/22 Page 19 of 28
Mail Lien Satisfaction to: Dept of Highway Safety and Motor Vehicles, Neil Klrkman Building, Tallahassee, FL 37399-0500

A03855

Identification Number

4C9WAHBG0MS092505

Year -

2021

- Make -

MOKE

Body

GC

— WT-L-BHP —

2200

Vessel Regis. No. -— Title Number -

142507325

■Icgistored Owner: Date of Issue 11/15/2021

I len Release

CHRISTOPHER TODD BLUDWORTH OR

ANDREW TODD MCNEILL

Mail To:

AUTO TAGS OF EAST BROWARD

1881 NE 26TH ST 95

FORT LAUDERDALE FL 33305-1427

Interest in the described vehicle is hereby released

By_______________________ ______

Title____________________________________

Date_________________

IMPORTANT INFORMATION

1. When ownership of the vehicle described herein is 

transferred, the seller MUST complete in full the

Transferof Title by Seller section at the bottom ot

the certificate of title2. Upon sale of this vehicle, the seller must complete

(he notice of sale on the reverse side of this form,

3. Remove your license plate from the vehicle.

4. See the web address below for more information and

the appropriate forms required forthe purchaser to 

title and register the vehicle, mobile home or vessel:

http://www.flhsmv.gov/html/titlinf.html

identification Number Year , Make Vessel Regis No Titfe Number

Uen Release Wj

Interest in the describes vehicle is hereby released

Prev Primary Brand

State

Secondary Brand

PRIVATE 05/04/2021

Odometer Status or Vessel Manufacturer or OH use Hull l.'alennl

253 MILES 11/11/2021 ACTUAL 11/15/2021

Registered Owner

CHRISTOPHER TODD BLUDWORTH OR

ANDREW TODD MCNEILL

1st Lienholder

NONE

DIVISION OF MOTORIST SERVICES FLORIDA DEPARTMENT OF HIGHWAY SAFETY AND MOTOR VEHICLES

154791038 Control Number

Terry L. Rhodes

Executive Director

Robert R. Kynoch

Director

------------------- TRANSFER OF TITLE BY SELLER (This section must be completed at the time of sale.) -------------------------

hcitcnil unA'or -lale law rc(|tiire tha! the seller -ialc (he mileye. pmhsscr's name, selling price and dale sold in connection with (hr transfer ul ownership.

Failure lo complete nr providing :■ tulsc otnienicni may rcoull in tines and,or imprixonineoL

Ibis title in wamniled tu be free from any liens e.\cepl ok noted on (tic luce ot’lhe ctrtiticiUe nod the motor vehicle or vessel described is hereby ImnHterred lo

Sel ler MiimI Jjiler Ihirchascr’.s Name

Seller Must Enter Selling Price: Seller Musi (Letter Date Sold

lAVe .stale Ihnt this [_j5or) li riiyil odlmictcr now reads I || || ||__||__||__I | ^ | {no lenlhs) miles, date read nod I hereby certify lh.il lo ihc hel ofniy knowledge ihc odometer readioc

n 1. reflectsACTUAl,MnJfACfe Q 2. is IN EXCESS OH ITS MECHANICAI. UMTTS. Q 3. isNOTTHEACWA!.

UNDER PENALTIES OF PERJURY. I DECLARE THAT I HAVE READ THE FOREGOING DOCUMENT AND THAT THE FACTS STATED IN IT ARE TRUE.

SELLER Mari eCKSHiJERMuri

Sign Hot:______ Sign Here:________________

Prtnl Here:

Dealer’s LicenseNombcr Tna Collected

I.icen.se Number:

WKCHASKR Must

Sijai Here:

Print Here-

(■t)-PIIKt:HASH!MlW

Siim Here:

Print Here

NOTICE: PENALTY IS REQUIRED BY LAW IF NOT SUBMITTED FOR TRANSFER WITHIN 30 DAYS AFTER DATE OF PURCHASE

^^CERTIFICATE QF. TITLE

^LIEN SATISFACTION

Case 22-12790-EPK Doc 121 Filed 05/27/22 Page 20 of 28
r-LUMlUA AU I UIVIUDILt INbUMAINUt IUCINIINUA I IUIM V^AttU

USAA CASUALTY INSURANCE COMPANY

POLICY IDENTIFICATION NO. CO. CODE EFF. DATE

00531 0224C 7105 0 -02865 11/11/21

Name

ANDREW TODD MC NEILL

CHRISTOPHER T BLUDWORTH

VEHICLE DESCRIPTION

fEAR MAKE/MODEL VEHICLE IDENTIFICATiON NUMBER

2021 MOKE 4C9WAHBG0MS092505

IOT VALID MORE THAN ONE YEAR FROM EFFECTIVE DATE

Misrepresentation ol Insurance is a first degree misdemeanor. Policy

coverages extend to a rental car. See outline ol coverage.

800 Fredericksburg Road 

an Antonio. Texas 78288

CONTACT US: 210-531-USAA(8722)

OR 800-531-USAA

A^Hitisvnol <*AA# otfoiloklo *+ • Ar-i

Case 22-12790-EPK Doc 121 Filed 05/27/22 Page 21 of 28
FLORIDA VEHICLE REGISTRATION

CO/AGY 10/4 T# 1555738297

B# 2675673

PLATE 81ATDK DECAL 17484632 Expires Midnight Wed 7/6/2022

YR/MK 2021/MOKE BODY GC

VIN 4C9WAHBG0MS092505

Plate Type RGS NET WT 2200

COLOR BLU

TITLE 142507325

DL/FFID

Date Issued 11/15/2021 Plate Issued 11/15/2021

2ND DL#

Reg Tax

Init. Reg. 

County Fee

Mail Fee 

Sales Tax

Voluntary' Fees

Grand Total

53 10 Class Code 1

225.00 Tax Months R

3 00 Back Tax Mos

Credit Class

Credit Months

281.10

CHRISTOPHER TODD BLUDWORTH, ANDREW TODD

MCNEILL

CALL OR TEXT: (954) 417-6130

WWW.BROWARDAUTOTAGS.COM

E-MAIL: info@browardautotag5.com

RENEWTAG BY PHONE WITH USI

IMPORTANT INFORMATION

1 The Florida license plate must remain with the registrant upon sale ofvehicle

2 The registration must be delivered to a Tax Collector or Tag Agent for transfer to 

a replacement vehicle.

3 Your registration must be updated to your new address within 30 days ofmoving

4 Registration renewals are the responsibility ofthe registrant and shall occur during

the 30-day period prior to the expiration date shown on this registration. Renewal

notices are provided as a courtesy and are not required for renewal purposes

5 I understand that my driver license and registrations will be suspended

immediately ifthe insurer denies the insurance information submitted

for this registration.

RGS - SUNSHINE STATE PLATE ISSUED X

Case 22-12790-EPK Doc 121 Filed 05/27/22 Page 22 of 28
EXHIBIT “C”

Case 22-12790-EPK Doc 121 Filed 05/27/22 Page 23 of 28
Text Screen Shots Between C Todd Bludworth and trustee Lawyer Nicole Mehdipour

12:40 <

<©

Nicole

Mon, Apr 11. 8:22 PM

Mr. Bludworth -thank you

for your message. I can

be reached via text in the

future at (954) 302-5937.

Please email me at my

business email address

nicolem@ntmlawfirm.com

and provide the car year,

make, model, Color, VIN

and copy of the title and

registration. Also include

where you last dropped

off the vehicle and the

reason. I will reply in short

order.

Bankruptcy Trustee Nicole

Mehdipour

a ©>

12:40-V

<©

Nicole

odiiiMupicy 11 usicc i>nt^uic

Mehdipour

Thank you for your quick

response. This is in regards to our Baby Blue

Moke picked up at o

house at

at 4pm on iuesday, April

5, 2022 He Moke is registered and owned by both

me and my husband, Andrew McNeill (also copied

on this email). Pick up for

service was arranged

through an individual

named Melton Melton's

name and number,

561-235-9105. were provided my Moke America

& a lext jssaqe

561-235-9105. were provided my Moke America

Service as a local serviceman for the brand The

Moke was picked up to replace the front tires, an

alignment and check the

charge on the batteries.

Attached is our vehicle

registration for the vehicle

as well as ourtitle. Please

call me with any

questions. Melton mentioned something about

being there at 12 30pm

tomorrow but we are in NY

for our kids Spring Break

until Sunday. Please let

me know what we need to

do. I have also attached a

12:41 V

<©

Nicole

12:41 f

<©

Nicole

questions. Melton mentioned something about

being there at 12:30pm

tomorrow but we are in NY

for our kids Spring Break

until Sunday. Please let

me know what we need to

do. I have also attached a

picture of our vehicle.

Thank you.

Todd Bludworth

Todd@americanmeetinas.com

Mobile: 954-553-2870

Ipii. ‘ ‘\

•Hji! !|:{l!l|:U l

G ©) Text Message

Receipt confirmed. I will

review. The vehicle is at

the premises and I am the

only person with the keys

and authorized to enter

the building. When you

are back in town please let

me know. Thank you.

We will back early next

week. Thank you.

Thu, Apr 21.1:41 PM

Hello Nicole. I have left a

phone message and

emailed about our Moke.

Please contact me as to

when we can pick up our

(3) ©> Text Message

Case 22-12790-EPK Doc 121 Filed 05/27/22 Page 24 of 28
Text Screen Shots Between C Todd Bludworth and trustee Lawyer Nicole Mehdipour

Nicole

Thu, Apr 21.1:41 PM

Hello Nicole. I have left a

phone message and

emailed about our Moke

Please contact me as to

when we can pick up our

vehicle

Fri, Apr 22.125 PM

Hello Nicole. I am attempting for a second

time to reach you regarding our Moke that you

have in your possession.

Please contact me ASAP

to make arrangements to

pick up. Thank you.

Sat, Apr 23. 6:09 PM

Case 22-12790-EPK Doc 121 Filed 05/27/22 Page 25 of 28
EXHIBIT “2”

Case 22-12790-EPK Doc 121 Filed 05/27/22 Page 26 of 28
UNITED STATES BANKRUPTCY COURT

SOUTHERN DISTRICT OF FLORIDA 

WEST PALM BEACH DIVISION 

www.flsb.uscourts.gov

IN RE: CASE NO.: 22-12790-EPK

EXCELL AUTO GROUP, INC., Chapter 7

ORDER GRANTING CHRISTOPHER TODD BLUDWORTH AND ANDREW

TODD McNEILL’S MOTION TO COMPEL TRUSTEE TO TURN OVER

NON-ESTATE PROPERTY. 2021 MOKE VEHICLE

THIS MATTER having come before the Court on the _____ day of June, 2022, at

__________a.m./p.m., in West Palm Beach, Florida, upon Christopher Todd Bladworth and

Andrew Todd McNeill's Motion to Compel Trustee to Turn Over Non-Estate Property, 2021

Moke Vehicle (the “Motion”) [ECF No.___]. The Court, having considered the Motion and the

Affidavit ofChristopher ToddBludworth in Support ofChristopher ToddBludworth andAndrew

Todd McNeill’s Motion to Compel Trustee to Turn Over Non-Estate Property, 2021 Moke

11432078-1

Case 22-12790-EPK Doc 121 Filed 05/27/22 Page 27 of 28
attached thereto as Exhibit “1”, having heard the argument of counsel, having determined that

the Moke1 is not property ofthe Debtor’s estate, and being otherwise fully advised does

ORDER as follows:

1. The Motion is GRANTED.

2. Within two (2) business days of entry of this Order on the Court’s docket, the

Trustee shall make the Moke available for retrieval by the Owners/Parties-in-Interest.

3. The Court retains the power to interpret and enforce this Order.

# # #

Submitted by:

Paul A. Avron, Esq.

BERGER SINGERMAN LLP

201 East Las Olas Boulevard, Suite 1500

Fort Lauderdale, FL 33301

Telephone: (954) 525-9900

Facsimile: (954) 523-2872

pavron@bergersingerman.com

Copies to:

Paul A. Avron, Esq.

(Attorney Avron is directed to serve this order upon all non-registered users or registered users

who have yet to appear electronically in this case andfile a conforming certificate ofservice.)

1 Capitalized terms used but not defined herein shall have the meanings ascribed in the Motion.

11432078-1

2

Case 22-12790-EPK Doc 121 Filed 05/27/22 Page 28 of 28