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UNITED STATES BANKRUPTCY COURT
SOUTHERN DISTRICT OF NEW YORK

In re:

NMP-GROUP, LLC,

Debtor.

Chapter 11

Case No. 13-



DECLARATION PURSUANT TO LOCAL RULE 1007-2

LUIZA DUBROVSKY, being duly sworn, deposes and says:

1.

I am manager of NMP-Group, LLC (the “Debtor”). As such, I am fully familiar

with the facts set forth herein and am duly authorized to submit this Declaration in support of the

petition by the Debtor for relief under chapter 11 of title 11 of the United States Code (the

“Bankruptcy Code”) filed on the date hereof (the “Petition Date”).

2.

I submit this Declaration pursuant to Rule 1007-2 of the Local Bankruptcy Rules

for the Southern District of New York (the “Local Rules”). Except as otherwise indicated, all

facts set forth in this Declaration are based upon my personal knowledge and my review of

relevant documents.

A.

The Debtor’s Business and Factors Precipitating the Chapter 11 Case

3.

The Debtor is a limited liability company organized on March 8, 2007 under the

laws of the State of New York. The Debtor was formed to acquire, own, improve, manage and

operate the real property known as 172-179 Madison Avenue (a/k/a 21 East 33rd Street) New

York, New York (the “Property”). The Property is intended for the development of a mixed-use

building for retail and condominiums.

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4.

On June 12, 2013, the Supreme Court of the State of New York, County of New

York entered a Judgment of Foreclosure and Sale (the “Foreclosure Judgment”) against the

Debtor in favor of 172 Madison (NY), LLC (the “Lender”). In accordance with the Foreclosure

Judgment, a public auction of the Property was scheduled for July 10, 2013 at 2:15 p.m. Facing

a foreclosure of the Property, the Debtor determined in the exercise of its business judgment that

filing for Chapter 11 protection was the best option to preserve the Property so that it can

proceed with a contract for sale in an orderly fashion.

B.

Information Required by Local Rule 1007-2(a)

5.

In accordance with Local Rule 1007-2(a)(2), no case has been previously been

filed by or against the Debtor under Chapters 7, 11, 13 or any other provision of the Bankruptcy

Code.

6.

In accordance with Local Rule 1007-2(a)(3), no creditors’ committee was

organized before the Petition Date.

7.

In accordance with Local Rule 1007-2(a)(4), the names and addresses of the

largest unsecured creditors appear on Exhibit A to this Declaration.

8.

In accordance with Local Rule 1007-2(a)(5), the names and addresses of the five

largest secured creditors appear on Exhibit B to this Declaration.

9.

In accordance with Local Rule 1007-2(a)(6), the Debtor has the following assets:

(a) the Property having an estimated value of approximately $68 million and (b) contingent,

unliquidated claims for the recovery of money. The Debtor has the following liabilities: (a)

secured claim to the Lender in accordance with the Foreclosure Judgment in the amount of

$51,645,270.72; (b) mechanics liens against the Property totaling $40,891.57; (c) liens against



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the Property for environmental and criminal violations totaling $26,500; and (d) miscellaneous

disputed, contingent and/or unliquidated unsecured claims.

10.

In accordance with Local Rule 1007-2(a)(7), the Debtor is not a publicly held

company.

11.

In accordance with Local Rules 1007-2(a)(8), and to the best of my knowledge,

information and belief, no property of the Debtor is in possession or custody of any custodian,

public officer, receiver, trustee, mortgagee, pledgee, assignee of rent, secured creditor or agent of

any of the foregoing.

12.

In accordance with Local Rule 1007-2(a)(9), the Debtor owns the Property. The

Debtor did not lease or otherwise hold any other arrangements for any premises from which its

business was operated.

13.

In accordance with Local Rule 1007-2(a)(10), the Property is located in New

York, New York. The books and records of the Debtor are in possession of Robert Blessey,

Esq., the Debtor’s former attorney. The Debtor does not have any assets located outside of the

United States.

14.

In accordance with Local Rule 1007-2(a)(11), the following actions are currently

pending against the Debtor: (a) Blane Fergus v. NMP-Group, LLC, Index No. 1543301/2013,

Supreme Court of the State of New York, County of New York; (b) Pasargad Carpets, Inc. v.

180 Madison Prisa II LLC, et al., Index No. 158200/2012, Supreme Court of the State of New

York, County of New York; and (c) 172 Madison (NY), LLC v. NMP-Group, LLC, et al., Index

No. 650087/2010, Supreme Court of the State of New York, County of New York.



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15.

In accordance with Local Rule 1007-2(a)(12), I am the manager of the Debtor and

have served in that capacity since May 2013. As manager, I am responsible for the day-to-day

affairs of the Debtor.

I hereby declare under penalty of perjury that the foregoing is true.

NMP-Group, LLC



By:

/s/ Luiza Dubrovsky
LUIZA DUBROVSKY



Dated: July 10, 2013



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EXHIBIT A

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B4 (Official Form 4) (12/07)

In re

NMP-Group, LLC

United States Bankruptcy Court

Southern District of New York

Debtor(s)

Case No.
Chapter

11

LIST OF CREDITORS HOLDING 20 LARGEST UNSECURED CLAIMS

Following is the list of the debtor's creditors holding the 20 largest unsecured claims. The list is prepared in

accordance with Fed. R. Bankr. P. 1007(d) for filing in this chapter 11 [or chapter 9] case. The list does not include (1)
persons who come within the definition of "insider" set forth in 11 U.S.C. § 101, or (2) secured creditors unless the value of
the collateral is such that the unsecured deficiency places the creditor among the holders of the 20 largest unsecured claims.
If a minor child is one of the creditors holding the 20 largest unsecured claims, state the child's initials and the name and
address of the child's parent or guardian, such as "A.B., a minor child, by John Doe, guardian." Do not disclose the child's
name. See 11 U.S.C. § 112; Fed. R. Bankr. P. 1007(m).

(1)

(2)

(3)

(4)

(5)

Name of creditor and complete
mailing address including zip
code

Name, telephone number and complete
mailing address, including zip code, of
employee, agent, or department of creditor
familiar with claim who may be contacted

Nature of claim (trade
debt, bank loan,
government contract,
etc.)

Clevenger Frable
39 Westmoreland Avenue
White Plains, NY 10606
Cosentini Associates
2 Pennsylvania Plaza
New York, NY 10121
DeSimone Consulting
Engineers, P.L.L.C.
18 West 18th St., 10th Fl.
New York, NY 10011
Blane Fergus
c/o Mark E. Seitelman, Esq.
111 Broadway, 9th Floor
New York, NY 10006
Gateway Demolition Inc.
134-22 32nd Avenue
Flushing, NY 11354
HRH Construction LLC
50 Main Street
15th Floor
White Plains, NY 10606
Israel Berger & Associates
360 Park Avenue South
New York, NY 10010
Jenkins & Huntington
1251 Avenue of the Americas
New York, NY 10020
Juscor Inc.
Attn: Edward A. Mermelstein
302 Fifth Avenue, 8th Floor
New York, NY 10001
Meridian Capital Group
Attn: Tal Bar-or
1 Battery Park Plaza
New York, NY 10004

Clevenger Frable
39 Westmoreland Avenue
White Plains, NY 10606
Cosentini Associates
2 Pennsylvania Plaza
New York, NY 10121
DeSimone Consulting
Engineers, P.L.L.C.
18 West 18th St., 10th Fl.
New York, NY 10011
Blane Fergus
c/o Mark E. Seitelman, Esq.
111 Broadway, 9th Floor
New York, NY 10006
Gateway Demolition Inc.
134-22 32nd Avenue
Flushing, NY 11354
HRH Construction LLC
50 Main Street
15th Floor
White Plains, NY 10606
Israel Berger & Associates
360 Park Avenue South
New York, NY 10010
Jenkins & Huntington
1251 Avenue of the Americas
New York, NY 10020
Juscor Inc.
Attn: Edward A. Mermelstein
302 Fifth Avenue, 8th Floor
New York, NY 10001
Meridian Capital Group
Attn: Tal Bar-or
1 Battery Park Plaza
New York, NY 10004

Indicate if claim is
contingent,
unliquidated,
disputed, or
subject to setoff

Contingent
Unliquidated
Disputed

Contingent
Unliquidated
Disputed

Contingent
Unliquidated
Disputed

Amount of claim
[if secured, also
state value of
security]

48.55

7,218.95

3,108.54

Unknown

60,014.55

100,000.00

11,962.12

18,750.00

Unknown

Unknown

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B4 (Official Form 4) (12/07) - Cont.
In re NMP-Group, LLC

Debtor(s)

Case No.

LIST OF CREDITORS HOLDING 20 LARGEST UNSECURED CLAIMS

(Continuation Sheet)

(1)

(2)

(3)

(4)

(5)

Name of creditor and complete
mailing address including zip
code

Name, telephone number and complete
mailing address, including zip code, of
employee, agent, or department of creditor
familiar with claim who may be contacted

Nature of claim (trade
debt, bank loan,
government contract,
etc.)

Metropolis
22 Cortlandt Street
New York, NY 10007
Mueser Rutledge
225 W. 34th Street
New York, NY 10122
Pasargad Carpets, Inc.
Jonathan Corbett, Weg &
Meyers
52 Duane Street
New York, NY 10007
Robert L. Blessey Law
Offices
51 Lyon Ridge Road
Katonah, NY 10536
SCAPE
227 Broadway, Suite 1606
New York, NY 10007
SLCE Architects
1359 Broadway
New York, NY 10018
Vibranalysis
3109 Kingsbridge Avenue
Bronx, NY 10463
Yates Restoration Group
Ltd.
36 Bruckner Blvd.
Bronx, NY 10454

Metropolis
22 Cortlandt Street
New York, NY 10007
Mueser Rutledge
225 W. 34th Street
New York, NY 10122
Pasargad Carpets, Inc.
Jonathan Corbett, Weg & Meyers
52 Duane Street
New York, NY 10007

Robert L. Blessey Law Offices
51 Lyon Ridge Road
Katonah, NY 10536

SCAPE
227 Broadway, Suite 1606
New York, NY 10007
SLCE Architects
1359 Broadway
New York, NY 10018
Vibranalysis
3109 Kingsbridge Avenue
Bronx, NY 10463
Yates Restoration Group Ltd.
36 Bruckner Blvd.
Bronx, NY 10454

Indicate if claim is
contingent,
unliquidated,
disputed, or
subject to setoff

Contingent
Unliquidated
Disputed

Contingent
Unliquidated
Disputed

Amount of claim
[if secured, also
state value of
security]

350.00

8,820.04

Unknown

Unknown

10,202.86

169,578.18

3,450.00

117,272.75

DECLARATION UNDER PENALTY OF PERJURY

ON BEHALF OF A CORPORATION OR PARTNERSHIP

I, the Manager of the corporation named as the debtor in this case, declare under penalty of perjury that I

have read the foregoing list and that it is true and correct to the best of my information and belief.

Date July 10, 2013

Signature

/s/ Luiza Dubrovsky
Luiza Dubrovsky
Manager

Penalty for making a false statement or concealing property: Fine of up to $500,000 or imprisonment for up to 5 years or both.

18 U.S.C. §§ 152 and 3571.

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EXHIBIT B












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NMP-GROUP, LLC

CASE NO. 13 -

CREDITORS HOLDING SECURED CLAIMS





Creditor's Name And Mailing Address

172 Madison (NY) LLC
John Doherty, Esq.
Alston & Bird LLP
90 Park Avenue
New York, NY 10016-1387

Circle Rose Contracting Inc.
125 Charles Street
Massapequa, NY 11758

Criminal Court of the City of New York
100 Centre Street
New York, NY 10013

Environmental Control Board
City of New York
66 John Street, Floor 10
New York, NY 10038-3772

Perimeter Bridges & Scaffold Co.
55 Cumberland Street
Rockville Centre, NY 11570

Suzanne M. Berger, Esq.
Referee
Bryan Cave LLP
1290 Avenue of the Americas
New York NY 10104

Amount Of Claim
Without Deducting
Value Of Collateral

$51,645,270.72

$26,130.00

$20,000.00

$1,500.00

$15,329.46

$6,578.24

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