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REQUEST FOR SPECIAL NOTICE AND SERVICE OF PAPERS AND RESERVATIONS OF RIGHTS

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Melbalynn Fisher, Esq. (SBN 114230)

GHIDOTTI | BERGER LLP 

1031 North Miami Beach Boulevard 

North Miami Beach, FL 33162 

Tel: (305) 501-2808

Fax: (954) 780-5578

bknotifications@ghidottiberger.com

Attorneys for Creditor

U.S. Bank Trust National Association, not in its individual capacity but solely as trustee for 

Igloo Series V Trust

UNITED STATES BANKRUPTCY COURT

SOUTHERN DISTRICT OF FLORIDA– WEST PALM BEACH DIVISION

In Re:

William Bradley Langel

Jamie Claire Langel,

 

 Debtors.

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Case No.: 21-11213-MAM

CHAPTER 13

U.S. Bank Trust National Association, 

not in its individual capacity but solely as 

trustee for Igloo Series V Trust

REQUEST FOR SPECIAL NOTICE

TO: UNITED STATES BANKRUPTCY JUDGE, THE DEBTOR, AND ALL 

INTERESTED PARTIES 

PLEASE TAKE NOTICE that GHIDOTTI BERGER LLP attorneys for U.S. Bank 

Trust National Association, not in its individual capacity but solely as trustee for Igloo Series V 

Trust, 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 above referenced 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, 

Case 21-11213-MAM Doc 128 Filed 05/10/22 Page 1 of 4
 

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REQUEST FOR SPECIAL NOTICE AND SERVICE OF PAPERS AND RESERVATIONS OF RIGHTS

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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 abovereferenced bankruptcy court. 

GHIDOTTI BERGER LLP, requests that for all notice purposes and for inclusion in the

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

Melbalynn Fisher, Esq. (SBN 114230)

GHIDOTTI | BERGER LLP 

1031 North Miami Beach Boulevard 

North Miami Beach, FL 33162 

Tel: (305) 501-2808 Fax: (954) 780-5578

bknotifications@ghidottiberger.com

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 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 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; 

c. 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 

d. 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. 

//

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Case 21-11213-MAM Doc 128 Filed 05/10/22 Page 2 of 4
 

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REQUEST FOR SPECIAL NOTICE AND SERVICE OF PAPERS AND RESERVATIONS OF RIGHTS

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All of the above rights are expressly reserved and preserved by this party without 

exception and with no purpose of confessing or conceding jurisdiction in any way by this filing 

or by any other participation in these matters. 

 GHIDOTTI | BERGER LLP

Dated: May 10, 2022 By:/s/ Melbalynn Fisher, Esq.

Melbalynn Fisher, ESQ.

U.S. Bank Trust National Association, not in its 

individual capacity but solely as trustee for Igloo 

Series V Trust

Case 21-11213-MAM Doc 128 Filed 05/10/22 Page 3 of 4
CERTIFICATE OF SERVICE

On May 10, 2022, I served the foregoing documents described as request for special notice on the 

following individuals by electronic means through the Court’s ECF program:

Justin Andrew Lefko justin@htllfirm.com

Colin V Lloyd ecolin@hosklaw.com, lloydcr97422@notify.bestcase.com

Nicole M Noel bankruptcynotices@kasslaw.com, nmnoel@ecf.courtdrive.com

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

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

Robin R Weiner ecf@ch13weiner.com, ecf2@ch13weiner.com

I declare under penalty of perjury under the laws of the United States of America that the 

foregoing is true and correct.

/s/ Kaitlyn May

Kaitlyn May

On May 10, 2022, I served the foregoing documents described as request for special notice on the 

following individuals by depositing true copies thereof in the United States mail at Santa Ana, California 

enclosed in a sealed envelope, with postage paid, addressed as follows: 

DEBTOR

William Bradley Langel and Jamie Claire Langel

1881 SE Camden St.

Port Saint Lucie, FL 34952

I declare under penalty of perjury under the laws of the United States of America that the 

foregoing is true and correct.

/s/ Kaitlyn May

Kaitlyn May

Case 21-11213-MAM Doc 128 Filed 05/10/22 Page 4 of 4