Filing # 233511614 E-Filed 10/13/2025 02:29:52 PM
`
`IN THE CIRCUIT COURT OF THE
`ELEVENTH JUDICIAL CIRCUIT IN AND
`FOR MIAMI-DADE COUNTY, FLORIDA
`
`CIVIL DIVISION
`KUNAL JERATH,
`CASE NO.: 2024-008658-CA-01
`Plaintiff/Judgment Debtor,
`V.
`
`ANTHONY BUCHER, et al,
`
`Defendant.
`
`RECEIVER’S AGREED EX PARTE MOTION TO DISCHARGE
`AND RELEASE RECEIVER AND TERMINATE RECEIVERSHIP
`
`Drew M. Dillworth, court appointed receiver (“Receiver”) for Hitmaker Music Group
`
`LLC, Hitmaker Services Inc., and Cluttered App LLC (collectively, the “Receivership Entities”),
`
`by and through undersigned counsel, moves the Court for entry of an Order (“Motion”)
`terminating the receivership initiated by this Court’s Post Judgment Order Appointing Receiver
`
`(“Receiver Order”) [D.E. 37] pursuant to the compromise reached by the parties [D.E. 150], and
`
`in support thereof, respectfully states as follows:
`FINAL REPORT AND ACCOUNTING
`1. The Court entered its Receiver Order on November 14, 2024, which, inter alia,
`appointed Mr. Dillworth as Receiver, and tasked him with the power and authority to preserve
`and protect the receivership property.
`2. The judgment [D.E. 1] against Mr. Bucher is for $1,308,249.96 and costs and
`expenses (the “Judgment”), which was entered in Indiana on January 9, 2014, and is accruing
`
`interest at the legal rate.
`
`
`
`
`
`
`
`
`3. The judgment creditor domesticated the judgment in Miami-Dade County, Florida
`on or about May 14, 2024, began collection activities, and subsequently obtained judgments
`against the Receivership Entities. Thereafter, the judgment creditor obtained the Receiver Order.
`
`4. Based on the Receiver’s investigation of the assets and liabilities of the
`Receivership Entities, Mr. Dillworth learned that Mr. Bucher, through the Receivership Entities,
`holds themselves out to the consuming public as a music distribution company. Nevertheless,
`subpoenas and correspondences to all of the major music streaming companies (Spotify,
`YouTube, Apple, Amazon, and Tidal) published on the Receivership Entities’ website
`
`(www.hitmakermusicgroup.com) returned no hits (pun intended).
`
`5. With the help of the judgment creditor, Mr. Dillworth was able to locate a
`mortgage encumbering property in the Northern District of Florida in the name of one of the
`Receivership Entities, Cluttered App LLC. Through a subpoena to that financial institution
`served in April of this year, Mr. Dillworth learned of several millions of dollars flowing through
`accounts of the Receivership Entities at that financial institution. Mr. Dillworth alerted the
`financial institution of the Receiver Order and put a directional freeze on those accounts.
`
`6. Mr. Dillworth also alerted Warner Music Group Corp (“WMG”) (the payee of the
`substantial sums of monies flowing through the Receivership Entities’ accounts) of the Receiver
`Order and requested information regarding the relationship of the Receivership Entities to the
`music publishing company.
`
`7. Subsequently, Mr. Bucher sought relief from the underlying Judgment and to
`vacate the Receiver Order. As a consequence, and even though the Receiver had reached
`
`agreement from WMG and the financial institution on turnover, the Receiver agreed to pause his
`
`
`
`
`
`
`
`
`administration of the estate until the Court had an opportunity to review — a decision the Court
`agreed was a proper use of his business judgment.
`
`8. Thereafter, the judgment creditor and the judgment debtor attended a mediation
`(without the Receiver) and reached a confidential settlement which called for, among other
`things, the termination of the receivership upon the initial settlement payment to the judgment
`creditor. Although the settlement terms are confidential, the Receiver is authorized to disclose
`that the initial payment is sufficient to pay the Receiver’s fees and expenses set forth below.
`
`0. The receiver understands that the initial payment has been made.
`
`10. In connection with the services rendered in this case, the Receiver and his
`professionals have incurred in excess of $57,000 in fees and expenses. However, in order to
`increase the distribution to the judgment creditor in this case, the Receiver has agreed to cap the
`administrative expenses of the estate to $50,000.
`
`11. Below is a chart of the Receiver’s final accounting for ease of reference:
`
`Recoveries
`Settlement Proceeds confidential
`Cash $0.00
`(A) Total Recoveries confidential
`Expenses Paid
`(B) Total Expenses Paid | $0.00
`
`Available Cash (A-B) | $0.00
`Administrative Expenses
`SWM fees and expenses | $50,000.00
`Proposed Distribution
`Judgment Creditor | $0.00
`
`Basis for Relief Requested
`12. The Receiver proposes, and the parties agree, to allow the Receiver’s discounted
`administrative expenses set forth below and to have them paid by the judgment creditor from the
`
`settlement proceeds.
`
`
`
`
`
`
`
`
`13. In connection with the foregoing activities, the Receiver and his law firm, Stearns
`Weaver Miller Weissler Alhadeff & Sitterson, P.A. (together, “SWM”) incurred fees and
`expenses. in excess of $57,000.00.
`
`14. The administrative expenses of the receivership estate are a fraction of the
`recoveries achieved and will result in a distribution to the judgment creditor. The receivership
`was pending for approximately 10 months and the Receiver and his professionals faithfully
`carried out the duties of the Receivership Order over that time. Those services included: (i)
`investigating the assets and liabilities of the Receivership Entities, (ii) investigating the
`Receivership Entities primary assets which include distribution agreements with WMG, and (iii)
`negotiating turnover of funds owed to the Receivership Entities from WMG and the
`Receivership Entities’ primary financial institution. The foregoing issues were all complex and
`time consuming.
`
`15. The compensation is reasonable and consistent with Hensley v. Eckerhart, 461
`U.S. 424, 433 (1983); Blum v. Stenson, 465 U.S. 886, 897 (1984); Pennsylvania v. Delaware
`Valley Citizens’ Counsel for Clean Air, 478 U.S. 546 (1986); and Norman v. Housing Authority
`of Montgomery, 836 F.2d 1292, 1299 (11th Cir. 1988). Indeed, they are relatively modest given
`the complexity of the services rendered, the character of the property involved, the amount of
`money coming into the Receiver’s hands, the time and responsibility involved, and the beneficial
`results achieved. Lewis v. Gramil Corp., 94 So.2d 174, 177 (Fla.1957).
`
`16. In light of the foregoing, there is no further need for the Receiver in this case and
`there are no further duties to be completed by the Receiver. Accordingly, Receiver seeks
`
`discharge by this Court and relief of any further duties and termination of the receivership.
`
`
`
`
`
`
`
`
`17. Throughout the course of this case, the Receiver satisfactorily performed his
`duties under the Receivership Order and preserved, protected and maintained the receivership
`property.
`
`18. ~Accordingly, the Receiver submits for the Court’s consideration the proposed
`“Order Discharging and Releasing Receiver, and Terminating Receivership” attached as Exhibit
`A and respectfully moves the Court to enter the Order.
`
`19. The judgment creditor and judgment debtor consent to the relief requested in this
`Motion.
`
`WHEREFORE, Receiver seeks entry of an Order granting this Motion, substantially in
`the form attached as Exhibit A and any further and other relief as the Court deems just and
`proper under the circumstances.
`
`Dated: October 13, 2025.
`
`Respectfully submitted,
`
`/s/ Eric J. Silver
`
`Eric J. Silver, Esq.
`
`Florida Bar Number 057262
`
`STEARNS WEAVER MILLER
`WEISSLER ALHADEFF & SITTERSON, P.A.
`
`Museum Tower, Suite 2200
`150 West Flagler Street
`
`Miami, Florida 33130
`
`Telephone: (305) 789-3200
`
`Facsimile: (305) 789-3395
`
`esilver(@stearnsweaver.com
`
`
`
`
`
`
`
`
`
`EXHIBIT A
`
`
`
`
`
`
`
`
`IN THE CIRCUIT COURT OF THE
`ELEVENTH JUDICIAL CIRCUIT IN AND
`FOR MIAMI-DADE COUNTY, FLORIDA
`
`CIVIL DIVISION
`KUNAL JERATH,
`CASE NO.: 2024-008658-CA-01
`Plaintiff/Judgment Debtor,
`V.
`
`ANTHONY BUCHER, et al,
`
`Defendant.
`
`ORDER GRANTING AGREED EX PARTE MOTION TO DISCHARGE
`AND RELEASE RECEIVER AND TERMINATE RECEIVERSHIP
`
`THIS CAUSE came before the Court upon the Agreed Ex Parte Motion to Discharge and
`
`Release Receiver and Terminate Receivership (the “Motion”) filed by Drew M. Dillworth, the
`
`receiver herein (“Receiver”).! Upon consideration of the Motion and the record of this matter,
`and noting the agreement of the Parties, the Court finds good cause to grant the Motion.
`Therefore —
`
`IT IS ORDERED that the Motion is GRANTED as follows:
`
`1. The Receiver’s final report and accounting is APPROVED.
`
`2. Receiver is DISCHARGED and RELEASED from any further responsibilities
`with regard to the receivership property and the Receiver Order.
`
`3. Receiver’s acts, transactions, and all of his actions during his administration
`disclosed in the pleadings filed with this Court are RATIFIED as right, proper, and in the best
`
`interest of the receivership estate and the parties to this action.
`
`! All capitalized terms not defined herein shall have the meanings ascribed to them in the Motion.
`
`6
`
`
`
`
`
`
`
`
`4. Receiver is DISCHARGED and RELEASED from liability for any and all acts
`occurring subsequent to the date of this Order.
`
`5. Any and all actions of the (i) Receiver, (ii) any party acting under the authority or
`direction of the Receiver taken at any time during the pendency of the receivership, including
`without limitation (a) the Receiver’s employees, (b) Receiver’s legal counsel and accountants,
`(c) Receiver’s agents, and (iii) each of such parties’ (i.e. the parties identified in (i) and (ii))
`respective agents, employees, and affiliates (collectively, all the foregoing referred to as
`
`“Released Parties”) are hereby RELEASED an ABSOLVED of and from any and all claims
`
`arising from the performance of the obligations imposed by the Court in the Receivership Order
`or otherwise.
`
`6. The final administrative fees and expenses set forth in Receiver’s Motion are
`APPROVED and CONFIRMED and ALLOWED. Immediately upon entry of this Order, the
`Receiver (and/or Judgment Creditor) is AUTHORIZED and DIRECTED to pay the distribution
`and the amounts awarded as contemplated under this Order and the Receivership Order.
`
`7. The receivership is TERMINATED and the receivership estate is CLOSED.
`
`8. The Receiver is AUTHORIZED and EMPOWERED to take any and all actions
`(including the execution, delivery, filing and/or recordation of any and all documents and
`instruments and the payment of any and all amounts) as may be necessary to finalize the
`administration of this receiverships as provided herein.
`
`0. The Receiver is AUTHORIZED and DIRECTED to implement the terms of this
`Order immediately upon entry by the Court.
`
`10. The Court shall retain jurisdiction over any matter arising from or relating to the
`
`interpretation or implementation of this Order.
`
`
`
`
`
`
`
`
`DONE and ORDERED in Chambers at Miami-Dade County, Florida, on October
`
`2025.
`
`Circuit Court Judge
`Copies furnished to:
`
`Counsel of record
`
`#14105098 v1
`
`
`
`
`
`
`
`
`
`
`IN THE CIRCUIT COURT OF THE
`ELEVENTH JUDICIAL CIRCUIT IN AND
`FOR MIAMI-DADE COUNTY, FLORIDA
`
`CIVIL DIVISION
`KUNAL JERATH,
`CASE NO.: 2024-008658-CA-01
`Plaintiff/Judgment Debtor,
`V.
`
`ANTHONY BUCHER, et al,
`
`Defendant.
`
`RECEIVER’S AGREED EX PARTE MOTION TO DISCHARGE
`AND RELEASE RECEIVER AND TERMINATE RECEIVERSHIP
`
`Drew M. Dillworth, court appointed receiver (“Receiver”) for Hitmaker Music Group
`
`LLC, Hitmaker Services Inc., and Cluttered App LLC (collectively, the “Receivership Entities”),
`
`by and through undersigned counsel, moves the Court for entry of an Order (“Motion”)
`terminating the receivership initiated by this Court’s Post Judgment Order Appointing Receiver
`
`(“Receiver Order”) [D.E. 37] pursuant to the compromise reached by the parties [D.E. 150], and
`
`in support thereof, respectfully states as follows:
`FINAL REPORT AND ACCOUNTING
`1. The Court entered its Receiver Order on November 14, 2024, which, inter alia,
`appointed Mr. Dillworth as Receiver, and tasked him with the power and authority to preserve
`and protect the receivership property.
`2. The judgment [D.E. 1] against Mr. Bucher is for $1,308,249.96 and costs and
`expenses (the “Judgment”), which was entered in Indiana on January 9, 2014, and is accruing
`
`interest at the legal rate.
`
`
`
`
`
`
`
`
`3. The judgment creditor domesticated the judgment in Miami-Dade County, Florida
`on or about May 14, 2024, began collection activities, and subsequently obtained judgments
`against the Receivership Entities. Thereafter, the judgment creditor obtained the Receiver Order.
`
`4. Based on the Receiver’s investigation of the assets and liabilities of the
`Receivership Entities, Mr. Dillworth learned that Mr. Bucher, through the Receivership Entities,
`holds themselves out to the consuming public as a music distribution company. Nevertheless,
`subpoenas and correspondences to all of the major music streaming companies (Spotify,
`YouTube, Apple, Amazon, and Tidal) published on the Receivership Entities’ website
`
`(www.hitmakermusicgroup.com) returned no hits (pun intended).
`
`5. With the help of the judgment creditor, Mr. Dillworth was able to locate a
`mortgage encumbering property in the Northern District of Florida in the name of one of the
`Receivership Entities, Cluttered App LLC. Through a subpoena to that financial institution
`served in April of this year, Mr. Dillworth learned of several millions of dollars flowing through
`accounts of the Receivership Entities at that financial institution. Mr. Dillworth alerted the
`financial institution of the Receiver Order and put a directional freeze on those accounts.
`
`6. Mr. Dillworth also alerted Warner Music Group Corp (“WMG”) (the payee of the
`substantial sums of monies flowing through the Receivership Entities’ accounts) of the Receiver
`Order and requested information regarding the relationship of the Receivership Entities to the
`music publishing company.
`
`7. Subsequently, Mr. Bucher sought relief from the underlying Judgment and to
`vacate the Receiver Order. As a consequence, and even though the Receiver had reached
`
`agreement from WMG and the financial institution on turnover, the Receiver agreed to pause his
`
`
`
`
`
`
`
`
`administration of the estate until the Court had an opportunity to review — a decision the Court
`agreed was a proper use of his business judgment.
`
`8. Thereafter, the judgment creditor and the judgment debtor attended a mediation
`(without the Receiver) and reached a confidential settlement which called for, among other
`things, the termination of the receivership upon the initial settlement payment to the judgment
`creditor. Although the settlement terms are confidential, the Receiver is authorized to disclose
`that the initial payment is sufficient to pay the Receiver’s fees and expenses set forth below.
`
`0. The receiver understands that the initial payment has been made.
`
`10. In connection with the services rendered in this case, the Receiver and his
`professionals have incurred in excess of $57,000 in fees and expenses. However, in order to
`increase the distribution to the judgment creditor in this case, the Receiver has agreed to cap the
`administrative expenses of the estate to $50,000.
`
`11. Below is a chart of the Receiver’s final accounting for ease of reference:
`
`Recoveries
`Settlement Proceeds confidential
`Cash $0.00
`(A) Total Recoveries confidential
`Expenses Paid
`(B) Total Expenses Paid | $0.00
`
`Available Cash (A-B) | $0.00
`Administrative Expenses
`SWM fees and expenses | $50,000.00
`Proposed Distribution
`Judgment Creditor | $0.00
`
`Basis for Relief Requested
`12. The Receiver proposes, and the parties agree, to allow the Receiver’s discounted
`administrative expenses set forth below and to have them paid by the judgment creditor from the
`
`settlement proceeds.
`
`
`
`
`
`
`
`
`13. In connection with the foregoing activities, the Receiver and his law firm, Stearns
`Weaver Miller Weissler Alhadeff & Sitterson, P.A. (together, “SWM”) incurred fees and
`expenses. in excess of $57,000.00.
`
`14. The administrative expenses of the receivership estate are a fraction of the
`recoveries achieved and will result in a distribution to the judgment creditor. The receivership
`was pending for approximately 10 months and the Receiver and his professionals faithfully
`carried out the duties of the Receivership Order over that time. Those services included: (i)
`investigating the assets and liabilities of the Receivership Entities, (ii) investigating the
`Receivership Entities primary assets which include distribution agreements with WMG, and (iii)
`negotiating turnover of funds owed to the Receivership Entities from WMG and the
`Receivership Entities’ primary financial institution. The foregoing issues were all complex and
`time consuming.
`
`15. The compensation is reasonable and consistent with Hensley v. Eckerhart, 461
`U.S. 424, 433 (1983); Blum v. Stenson, 465 U.S. 886, 897 (1984); Pennsylvania v. Delaware
`Valley Citizens’ Counsel for Clean Air, 478 U.S. 546 (1986); and Norman v. Housing Authority
`of Montgomery, 836 F.2d 1292, 1299 (11th Cir. 1988). Indeed, they are relatively modest given
`the complexity of the services rendered, the character of the property involved, the amount of
`money coming into the Receiver’s hands, the time and responsibility involved, and the beneficial
`results achieved. Lewis v. Gramil Corp., 94 So.2d 174, 177 (Fla.1957).
`
`16. In light of the foregoing, there is no further need for the Receiver in this case and
`there are no further duties to be completed by the Receiver. Accordingly, Receiver seeks
`
`discharge by this Court and relief of any further duties and termination of the receivership.
`
`
`
`
`
`
`
`
`17. Throughout the course of this case, the Receiver satisfactorily performed his
`duties under the Receivership Order and preserved, protected and maintained the receivership
`property.
`
`18. ~Accordingly, the Receiver submits for the Court’s consideration the proposed
`“Order Discharging and Releasing Receiver, and Terminating Receivership” attached as Exhibit
`A and respectfully moves the Court to enter the Order.
`
`19. The judgment creditor and judgment debtor consent to the relief requested in this
`Motion.
`
`WHEREFORE, Receiver seeks entry of an Order granting this Motion, substantially in
`the form attached as Exhibit A and any further and other relief as the Court deems just and
`proper under the circumstances.
`
`Dated: October 13, 2025.
`
`Respectfully submitted,
`
`/s/ Eric J. Silver
`
`Eric J. Silver, Esq.
`
`Florida Bar Number 057262
`
`STEARNS WEAVER MILLER
`WEISSLER ALHADEFF & SITTERSON, P.A.
`
`Museum Tower, Suite 2200
`150 West Flagler Street
`
`Miami, Florida 33130
`
`Telephone: (305) 789-3200
`
`Facsimile: (305) 789-3395
`
`esilver(@stearnsweaver.com
`
`
`
`
`
`
`
`
`
`EXHIBIT A
`
`
`
`
`
`
`
`
`IN THE CIRCUIT COURT OF THE
`ELEVENTH JUDICIAL CIRCUIT IN AND
`FOR MIAMI-DADE COUNTY, FLORIDA
`
`CIVIL DIVISION
`KUNAL JERATH,
`CASE NO.: 2024-008658-CA-01
`Plaintiff/Judgment Debtor,
`V.
`
`ANTHONY BUCHER, et al,
`
`Defendant.
`
`ORDER GRANTING AGREED EX PARTE MOTION TO DISCHARGE
`AND RELEASE RECEIVER AND TERMINATE RECEIVERSHIP
`
`THIS CAUSE came before the Court upon the Agreed Ex Parte Motion to Discharge and
`
`Release Receiver and Terminate Receivership (the “Motion”) filed by Drew M. Dillworth, the
`
`receiver herein (“Receiver”).! Upon consideration of the Motion and the record of this matter,
`and noting the agreement of the Parties, the Court finds good cause to grant the Motion.
`Therefore —
`
`IT IS ORDERED that the Motion is GRANTED as follows:
`
`1. The Receiver’s final report and accounting is APPROVED.
`
`2. Receiver is DISCHARGED and RELEASED from any further responsibilities
`with regard to the receivership property and the Receiver Order.
`
`3. Receiver’s acts, transactions, and all of his actions during his administration
`disclosed in the pleadings filed with this Court are RATIFIED as right, proper, and in the best
`
`interest of the receivership estate and the parties to this action.
`
`! All capitalized terms not defined herein shall have the meanings ascribed to them in the Motion.
`
`6
`
`
`
`
`
`
`
`
`4. Receiver is DISCHARGED and RELEASED from liability for any and all acts
`occurring subsequent to the date of this Order.
`
`5. Any and all actions of the (i) Receiver, (ii) any party acting under the authority or
`direction of the Receiver taken at any time during the pendency of the receivership, including
`without limitation (a) the Receiver’s employees, (b) Receiver’s legal counsel and accountants,
`(c) Receiver’s agents, and (iii) each of such parties’ (i.e. the parties identified in (i) and (ii))
`respective agents, employees, and affiliates (collectively, all the foregoing referred to as
`
`“Released Parties”) are hereby RELEASED an ABSOLVED of and from any and all claims
`
`arising from the performance of the obligations imposed by the Court in the Receivership Order
`or otherwise.
`
`6. The final administrative fees and expenses set forth in Receiver’s Motion are
`APPROVED and CONFIRMED and ALLOWED. Immediately upon entry of this Order, the
`Receiver (and/or Judgment Creditor) is AUTHORIZED and DIRECTED to pay the distribution
`and the amounts awarded as contemplated under this Order and the Receivership Order.
`
`7. The receivership is TERMINATED and the receivership estate is CLOSED.
`
`8. The Receiver is AUTHORIZED and EMPOWERED to take any and all actions
`(including the execution, delivery, filing and/or recordation of any and all documents and
`instruments and the payment of any and all amounts) as may be necessary to finalize the
`administration of this receiverships as provided herein.
`
`0. The Receiver is AUTHORIZED and DIRECTED to implement the terms of this
`Order immediately upon entry by the Court.
`
`10. The Court shall retain jurisdiction over any matter arising from or relating to the
`
`interpretation or implementation of this Order.
`
`
`
`
`
`
`
`
`DONE and ORDERED in Chambers at Miami-Dade County, Florida, on October
`
`2025.
`
`Circuit Court Judge
`Copies furnished to:
`
`Counsel of record
`
`#14105098 v1
`
`
`
`
`
`
`
`
`
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