UNITED STATES BANKRUPTCY COURT 

SOUTHERN DISTRICT OF FLORIDA 

www.flsb.uscourts.gov

West Palm Beach Division

 

In re: Case No. 22-10741-EPK 

Chapter 11 

 

BASA INVESTMENTS LLC 

 

 

 

 

 Debtor / 

 

DEBTOR-IN-POSSESSION’s APPLICATION FOR ORDER APPROVING 

EMPLOYMENT OF LAUDY LUNA, ESQ., AND CUNEO, REYES & LUNA LLC AS 

ATTORNEYS FOR THE DEBTOR, EFFECTIVE AS OF THE PETITION DATE

JANUARY 31, 2022 

BASA INVESTMENTS, LLC, Debtor-in-Possession (the “Debtor”) respectfully requests 

an order of the court approving the employment of Laudy Luna, Esq. and the law firm of Cuneo, 

Reyes & Luna LLC1, effective as of the date of the Chapter 11 Petition, January 31, 2022, to 

represent the Debtor in this case, and states as follows:

1. On January 31, 2022, the Debtor filed a Voluntary Petition under Chapter 11 of the United 

States Bankruptcy Code [ECF 1]. 

2. The Debtor desires to employ Laudy Luna, Esq. (the “Attorney”) and the firm of Cuneo, 

Reyes & Luna, LLC (the “Firm”) in this case.

3. The Debtor believes that the Attorney and Firm are qualified to practice in this court and are 

qualified to advise the Debtor on its relations with, and responsibilities to, the creditors and other interested 

parties.

 

1 As of February 1, 2022, the undersigned counsel’s firm changed it name from Reyes & Luna LLC, to Cuneo, Reyes 

& Luna, LLC. 

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Case No. 22-10741-EPK 

Chapter 11 

Cuneo, Reyes & Luna Law

2665 S. Le Jeune, Rd., Suite 804, Coral Gables, FL 33234 (786) 332-6787

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4. The professional services the Attorney and Firm will render are summarized as follows: 

(a) To give advice to the Debtor with respect to its powers and duties as a Debtor- inpossession and the continued management of business operations;

(b) To advise the Debtor with respect to its responsibilities in complying with the U.S. 

Trustee’s Operating Guidelines and Reporting Requirements and with the rules of the 

Court; 

(c) To prepare motions, pleadings, orders, applications, adversary proceedings, and other 

legal documents necessary in the administration of the case;

(d) To protect the interest of the Debtor in all matters pending before the Court; and 

(e) To represent the Debtor in negotiations with creditors in the preparation of a plan

connection with the creditors or other parties in interest or their respective attorneys. 

5. Neither the Attorney nor Firm represent any interest adverse to the Debtor. 

6. Attached to this motion is the Attorney's affidavit demonstrating the Attorney and the Firm are 

disinterested as required by 11 U.S.C. § 327(a), along with a verified statement as required under 

Bankruptcy Rule 2014. 

7. Pursuant to Local Rule 2014-1(A), a copy of the Retainer Agreement executed by the Debtor is 

attached hereto.

8. The Attorney and the Firm have agreed to be compensated in accordance with 11 U.S.C. § 330.

9. The Firm’s attorneys request compensation at the following hourly rate: 

a. Laudy Luna at $450.00 per hour; 

b. Jessica Reyes and Frank Cuneo, $450.00 per hour 

c. Associate attorneys $325.00 per hour 

d. Paralegals at $150.00 per hour 

10. Prior to the filing of this case, the debtor agreed to pay the Firm a retainer in the amount of 

$15,000.002

, which includes the filing fee of $1,738.00. The Debtor has authorized the use of the foregoing 

 

2 As reflected in the Retainer attached to this application the retainer amount is to be applied to three (3) bankruptcy 

cases which will be filed in this Court by the Debtor and 2 related entities. The Debtor and related debtors will seek 

the joint administration of the cases. 

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Case No. 22-10741-EPK 

Chapter 11 

Cuneo, Reyes & Luna Law

2665 S. Le Jeune, Rd., Suite 804, Coral Gables, FL 33234 (786) 332-6787

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retainer for pre-petition and post-petition services, with all post-petition services and cost subject to the 

Bankruptcy Court approval. 

WHEREFORE, the Debtor respectfully requests that this Court enter an Order authorizing the retention 

of Laudy Luna, Esq. and the law firm of Cuneo, Reyes & Luna, LLC, effective as of the Chapter 11 Petition 

Date, January 31, 2022, on a general retainer, pursuant to 11 U.S.C. §§ 327 and 330, and granting any 

further relief as this Court deems just and proper. 

Dated: February 28, 2022 BASA INVESTMENTS LLC

 Debtor in Possession

 

 By: _________________________

 Ariel Banegas, Managing Member of Debtor,

 Basa Investments, LLC

 

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a true copy of the foregoing will be furnished to all creditors 

and interested parties on the Official Court Matrix. 

 Respectfully submitted, 

 /s/ Laudy Luna__________ 

 Laudy Luna (FBN 044544) 

 Email: ll@crllawgroup.com 

 Cuneo, Reyes & Luna LLC 

 2655 S. Le jeune Rd., Suite 804 

 Coral Gables, Florida 33134 

 Tel: (786)332-6787 

 Fax: (786)204-0687 

 Counsel for Debtor, Basa Investments LLC. 

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Chapter 11 

Cuneo, Reyes & Luna Law

2665 S. Le Jeune, Rd., Suite 804, Coral Gables, FL 33234 (786) 332-6787

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CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a true copy of the foregoing will be furnished to all 

creditors, interested parties on the Official Court Matrix, and parties listed below via U.S. 

Mail. Additionally, this Application was furnished to the parties registered to receive 

C./ECF notices through the Court’s CM/ECF system. 

U.S. Trustee

Attn: Heidi A. Feinman 

Office of the US Trustee 

51 S.W. 1st Ave. 

Suite 1204

G. Steven Fender, Esq.

Fender, Bolling and Paiva, P.A.

P.O. Box 1545

Ft. Lauderdale, FL 33302

Telephone: (407) 810-2458

Email: steven.fender@fender-law.com

Hampton Peterson, Esq.

Palm Beach County Tax Collector’s Office 

P.O. Box 3715

West Palm Beach, Florida 33402-3715 

legalservices@pbctax.com

Newline Holdings, LLC 

PO Box 8719

Carol Stream, IL 60197

Respectfully submitted, 

/s/ Laudy Luna__________ 

Laudy Luna (FBN 044544) 

Email: ll@crllawgroup.com 

Cuneo, Reyes & Luna LLC 

2655 S. Le jeune Rd., Suite 804 

Coral Gables, Florida 33134 

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Case No. 22-10741-EPK 

Chapter 11 

Cuneo, Reyes & Luna Law

2665 S. Le Jeune, Rd., Suite 804, Coral Gables, FL 33234 (786) 332-6787

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Tel: (786)332-6787 

Fax: (786)204-0687 

Counsel for Debtor, Basa Investments LLC. 

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