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“the Property was heavily marketed”, the offer “was the highest and best offer received for the
Property”, that the Sale Agreement was “negotiated at arm’s length”, that the Sale Agreement
was “proposed in good faith”, that the “purchase price is fair and reasonable”, that “the price
was reached after an exhaustive marketing process”, and that “[t]he sale of the Property as
contemplated by the Sale Agreement, is in the best interest of Seaview, the Lender, and the
Property”. Mr. Goldwasser knew, or should have known, of the entry of the Order Approving
Sale, because the Order Approving Sale was entered on December 3, 2025, with Debtor filing its
bankruptcy petition on December 15, 2025, and filing the Goldwasser Declaration on December
18, 2025, some two weeks after the entry of the Order Approving Sale.
Rather, the Goldwasser Declaration reveals Debtor’s improper intent of circumventing or
voiding the Order Approving Sale wherein Debtor’s stated, “primary objective in this case is to
implement a transparent, court-supervised sale process that exposes the Property to the market on
a nationwide basis through the retention of an independent national commercial real estate
brokerage firm, with the goal of achieving the highest and best value.” See the Goldwasser
Declaration at paragraph 50. In short, Debtor and Mr. Goldwasser seek to unwind the Order
Approving Sale in a quixotic pursuit of a higher purchase price. After having slept on its rights
during the process of first securing the Property and then its sale, Debtor now conducts a legal
ambush outside of Virginia by way of its bankruptcy petition, in an ill-fated effort to return the
Property to Debtor and unravel the Order Approving Sale. Such conduct should be rejected with
FourLeaf and the Receiver excused from the provisions of 11 U.S.C. §543(a) and (b).
Case 25-23251-MEH Doc 18-20 Filed 12/22/25 Entered 12/22/25 20:08:18 Desc
Memorandum of Law Page 13 of 20
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