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Case 25-23251-MEH Doc 50 Filed 01/07/26 Entered 01/07/26 15:54:27 Desc Main
Document Page 8 of 12
In re Seaview Apartments LLC
Case No. 25-23251 (MEH)
approved by the Circuit Court when there was never a sincere object by the Debor to that sale
process before the Circuit Court. (See, e.g., FourLeaf’s Br. at 10-11, Doc. No. 26-20).
Significantly, to the extent that the Debtor now challenges the propriety of the Receiver
engaging the broker that it did, the broker was specifically identified in the Circuit Court’s Order
appointing the Receiver on February 11, 2025, nearly one year ago. (See Order Appointing Special
Receiver ¶ 3.g., Ex. 2 to Denton Decl., Doc. No. 26-15). The Debtor never objected to the
Receiver’s selection of a broker. To the extent that the Debtor now challenges the adequacy and
integrity of the sale process as whole, the transcript of the Circuit Court hearing on December 3,
2025, on the motion to approve the sale and the resulting order granting that motion, unequivocally
demonstrate that the Debtor had a full and fair opportunity to raise the perceived deficiencies with
the sale that it now belatedly and improperly raises in this Court. The Debtor, who was represented
by counsel in the receivership proceeding, did not do so and has slept on its rights.
At the hearing on the motion to approve the sale, FourLeaf’s counsel argued in favor of the
sale and its fairness, introducing evidence of such fairness and presenting testimony from Edward
Denton (“Mr. Denton”), the Receiver’s authorized representative of StreamCo Property
Resolutions. (See generally Hr’g Tr. Doc. No. 36). FourLeaf submitted declarations by Mr.
Denton in support of its current motions. (See, e.g., Denton Decl., Doc. No. 26-13). Mr. Denton
testified before the Circuit Court that he has experience in more than two dozen receivership cases
in the state of Virginia and North Carolina where property, including multi-family properties, has
been conveyed. (Hr’g Tr. 15:6-16:5, Doc. No. 36). Mr. Denton also testified as to the receiver’s
extensive marketing efforts of the Property, including an email marketing campaign to 794
prospective purchasers, brokers, and buyer representatives, as well as an online marketing
campaign that generated tens of thousands of impressions and thousands of user views. (Id. 17:3-
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