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In re Print Harmony, LLC

Citations: 567 B.R. 632; 27 Fla. L. Weekly Fed. B 27; 2017 Bankr. LEXIS 936Docket: Case No. 8:15-bk-06982-MGW

Court: United States Bankruptcy Court, M.D. Florida; April 4, 2017; Us Bankruptcy; United States Bankruptcy Court

Narrative Opinion Summary

In this legal dispute, the Debtor, a commercial wholesale internet printer, faced a claim from Rubin Automobile Boulevard, LLC, the Landlord, for unpaid rent and related damages under a triple net lease. The Landlord's proof of claim amounted to $676,713.05, citing unpaid rent, repair costs, and a breach of a purchase obligation. The Debtor contended that rent should be abated due to the Landlord's failure to provide insurance proceeds for flood-related repairs. The Court found the Landlord partially responsible for delaying repairs and failing to demonstrate the necessity of claimed repair costs. The Landlord's waiver of the purchase obligation was also determined. Ultimately, the Court awarded the Landlord a reduced claim of $123,169.21 for prepetition rent and $6,041.40 for postpetition rent. The Debtor's objection to other claims for repair and rejection damages was largely sustained, and the Landlord's motion to estimate its claim was deemed moot. The ruling emphasized the necessity of proving claims and the significance of lease terms in determining obligations and entitlements under Florida law.

Legal Issues Addressed

Administrative Expense Claims

Application: The Court approved the Landlord's postpetition rent claim, reduced by the proportion of the premises affected by flood damage, while rejecting other administrative expense claims due to lack of proof.

Reasoning: The Court rejected the first two claims for similar reasons as prior repair claims but approved the postpetition rent claim, reduced by 3.84% for flood damage, resulting in a total of $6,041.40.

Breach of Lease and Rent Abatement

Application: The Court determined that the Debtor is entitled to rent abatement proportional to the impairment of use, amounting to 3.84% of the unpaid prepetition rent, due to the Landlord's breach of the lease by not making insurance proceeds available for repairs.

Reasoning: The Court agrees that the Landlord breached the lease by failing to insure the premises.

Burden of Proof in Lease Dispute

Application: The Court found that the Landlord must prove its claims after the Debtor successfully rebuts the claim's validity since the Landlord initiated the contract lawsuit under Florida law.

Reasoning: Under Florida law, the party initiating a contract lawsuit bears the burden of proof.

Proof of Claim Requirements

Application: The Court noted that a proof of claim that meets Rule 3001 requirements serves as prima facie evidence of validity, shifting the burden to the Debtor to refute this.

Reasoning: It noted that a proof of claim meeting Rule 3001 requirements serves as prima facie evidence of validity, placing the burden on the Debtor to refute this.

Waiver of Purchase Obligation

Application: The Court found that the Landlord waived the claim for breach of the purchase obligation, as there was no demand for the Debtor to purchase the property, indicating a waiver of a known right.

Reasoning: The Landlord waived its claim for breach of the purchase obligation, as waiver under Florida law is defined as the intentional relinquishment of a known right.