Robert A. Mark

How Judge Mark rules, drawn from 12 signed orders. Every observation links to the order it came from.

Court
U.S. Bankruptcy Court for the Southern District of Florida
Position
Bankruptcy judge
Appointed by
U.S. Court of Appeals for the Eleventh Circuit
Commissioned
November 1, 1990
Education
Brandeis University, B.A., 1973; Boalt Hall School of Law, University of California, Berkeley, J.D., 1978
Signed orders read
12

About Judge Mark

Robert A. Mark has served as a United States Bankruptcy Judge for the Southern District of Florida since November 1990. He served as the court’s chief judge from 1999 through 2006. Before joining the bench, he clerked for a federal district judge and practiced bankruptcy law in Miami.

Judge Mark's practices and standing orders

Rules for cases before Judge Mark, as published on the court's website (checked October 10, 2026). Judges revise these often, so confirm the current version on the court's site before you file.

Key rules

Motions

Outside permitted Chapter 7 and 13 self-calendaring, the courtroom deputy exclusively maintains Judge Mark’s calendar.

“With the exception of certain Chapter 7 and Chapter 13 matters that may be self-calendared (see Guidelines for Self-Calendaring ), Judge Mark’s calendar is maintained exclusively by the Courtroom Deputy.”

Conferences

Video-conference participants must register at least 24 hours ahead, or one hour ahead for an emergency hearing.

“Participants must register at least 24 hours prior to the hearing, except for hearings set on an emergency basis, in which case participants must register at least one hour prior to the hearing.”

Trial

Unless a separate order says otherwise, witnesses and examining counsel must appear in court.

“Unless otherwise directed by separate order, Judge Mark requires in-court appearance for all witnesses and all counsel who will be examining or cross-examining witnesses.”

Standing orders for every case in this court

Orders the court applies to all of its cases, whichever judge has them, as published on the court's website (checked October 10, 2026).

Key rules from these orders · The court's local rules ↗

How Judge Mark decides

Patterns drawn from this judge's own signed orders. Every observation links to the order it came from.

What persuades

Clear statutory language controls even when its application produces an unusual distinction.

“But unusual is not the same as absurd. By its plain and unambiguous terms, the domestic violence exception applies to any civil action ‘regarding domestic violence.’”

In a tax-sale dispute, Mark held that the debtor’s equitable rights and colorable title claim brought the home within the bankruptcy estate despite the absence of record title.

“the Debtor has at least equitable rights in the Home and viable claims to establish”

Procedural preferences

A remote examination complies with the subpoena-distance rule when the witness participates from a location within the geographic limit.

“Instead, and as discussed earlier, the Court concludes that a Zoom examination from a location within 100 miles of where a witness resides is an appropriate place of compliance.”

Cautions

Creditors who receive notice cannot disregard a proof-of-claim deadline and expect to share in a later distribution.

“But deadlines matter in bankruptcy cases. The Objecting Creditors failed to timely file proofs of claim despite receiving notice of the deadline and there is no legal basis to allow them to file their claims now.”

Signed rulings

A grounded sample of orders signed by this judge, with the verbatim dispositive language.

In re Christopher Michael Borchetta
25-12808-RAM · 2025-11-04
Motion for protective order and to quash rule 2004 subpoena (Adelle Borchetta) Denied

“The Motions for Protective Order [DE#’s 58 and 69] are denied.”

Motion for protective order and to quash rule 2004 subpoena (Andrew Fromm) Denied
In re 942 Penn RR, LLC; In re DRO 15R LLC; DRO 15R LLC v. Ajar Holdings, LLC
22-14038-RAM; 22-12017-RAM; 22-01130-RAM · 2025-05-23
Motion for recusal or disqualification (Raziel Ofer) Denied

“For these reasons, the Court ORDERS that the Motions for Recusal are denied.”

Motion for recusal or disqualification (Raziel Ofer) Denied
In re George E. Robb, Jr.
24-20951-RAM · 2025-04-25
Motion to determine state court judgment void for stay violation (George E. Robb, Jr.) Denied

“The Debtor’s Motion [DE# 73] is denied.”

Request to retroactively annul automatic stay (Dorothy Farrell) Moot / procedural

“The request in Ms. Farrell’s Response in Opposition [DE# 99] to retroactively annul the automatic stay is denied without prejudice as moot.”

In re SAM Industrias S.A., Boulder Participacoes, Ltda., and Daniel Bensayag Birmann
18-23941-BKC-RAM · 2023-07-26
Second motion to compel production (foreign representative) Granted in part

“The Second Motion to Compel is granted in part and as detailed herein, the Respondents must produce unredacted copies of the Withheld Documents identified as Log Entries 1, 2, 13, 14, 36, 43, 46 and 47, and Wiggin 0121-122”

In re Sanomedics, Inc.
16-21659-RAM · 2023-11-27
Objection to final report and motion to file untimely claim (Nathan Boyer) Denied

“All the Objections [DE#s 479, 482, 487, 491, 492 and 494] are overruled.”

Objection to final report and motion to file untimely claim (Dan Truckey) Denied
Objection to final report and motion to file untimely claim (Curtis Ross) Denied
Motion to file untimely proof of claim (Peter Creelman) Denied
Objection to final report and motion to file untimely claim (David DeBlauw) Denied
Objection to final report (Curtis Ross) Denied
In re Sundale, Ltd. and Kendall Hotel and Suites, LLC
07-21016-BKC-RAM; 08-11050-BKC-RAM · 2021-08-03
Motion to liquidate attorneys fees and costs (Van Beuren Management) Granted in part

“VBM is awarded attorney’s fees and costs in the amount of $45,000.00.”

In re Sundale, Ltd. and Kendall Hotel and Suites, LLC
07-21016-BKC-RAM; 08-11050-BKC-RAM · 2021-04-19
Motion to reopen chapter 7 case (Sundale, Ltd., Kendall Hotel and Suites, LLC, and Philip Scutieri) Denied

“The Motion to Reopen is denied.”

Motion to vacate orders and judgments under rule 60 b (Sundale, Ltd., Kendall Hotel and Suites, LLC, and Philip Scutieri) Denied

“The Motion to Vacate is denied.”

In re Sanomedics, Inc.
16-21659-RAM · 2018-07-24
Motion to reconsider discovery orders (KIPU Systems, LLC) Denied

“ORDERED that the Motion to Reconsider is denied in its entirety.”

In re Sixty One Sixty, LLC
17-23573-BKC-RAM · 2018-04-11
Request for rule 9011 sanctions (The Schecher Group, Inc.) Denied

“The Motion is denied to the extent it requests a sanctions award under Fed. R. Bankr. P. 9011.”

Motion to set sanctions hearing (The Schecher Group, Inc.) Moot / procedural

“The Motion to Set Hearing is denied as moot.”

In re Javier A. Orozco and Georgina M. Orozco
09-34626-BKC-RAM · 2011-07-30
Objection to claim 1 (Javier A. Orozco and Georgina M. Orozco) Granted

“Debtors’ Objection to Claim No. 1 [DE# 79] is sustained and Claim No. 1 is stricken.”

Objection to claim 10 (Javier A. Orozco and Georgina M. Orozco) Granted

“Debtors’ Objection to Claim No. 10 [DE# 77] is sustained and Claim No. 10 is stricken.”

Objection to claim 5 (Javier A. Orozco and Georgina M. Orozco) Granted in part

“Debtors’ Objection to Claim No. 5 [DE# 85] is sustained in part to the extent the claim amount exceeds the scheduled amount.”

Objection to claim 3 (Javier A. Orozco and Georgina M. Orozco) Granted in part

“Debtors’ Objection to Claim No. 3 [DE# 75] is sustained in part and overruled in part.”

Objections to claims 13 and 14 (Javier A. Orozco and Georgina M. Orozco) Granted in part

“Debtors’ Objection to Claims No. 13 and No. 14 [DE# 83] is sustained in part and overruled in part.”

Objection to claim 4 (Javier A. Orozco and Georgina M. Orozco) Denied

“Debtors’ Objection to Claim No. 4 [DE# 81] is overruled.”

Objection to claim 12 (Javier A. Orozco and Georgina M. Orozco) Granted in part

“Debtors’ Objection to Claim No. 12 [DE# 82] is sustained in part and overruled in part.”

In re Freeman Kelley, Jr.
25-15370-RAM · 2026-02-04
Motion to declare stay inapplicable or annul (tax-sale purchaser) Denied

“The Stay Relief Motion is denied.”

Motion to enforce automatic stay (debtor) Granted

“The Motion to Enforce Stay is granted. The automatic stay applied to the Tax”

In re Motoro Cars III, LLC
26-16855-RAM · 2026-06-03
Motion to declare stay inapplicable (landlord) Denied

“The Motion is denied to the extent it seeks a finding that the subject lease was”

Draft for Judge Mark with the record in hand

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