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Seaview: FourLeaf’s adequate-protection memorandum, ECF 18-20

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15 8737319.1 Crexi, and CoStar. These listing services are utilized by most commercial real estate investors and brokers in the United States. See the Denton Declaration at paragraph 38. The listings generated more than 10,000 direct engagements and more than 1,900 users viewed the property specific details and offering information. Significantly, forty non-disclosure agreements were executed, including with individuals from Florida, Illinois and Texas, among others. See the Denton Declaration at paragraphs 38 and 39. As noted by Mr. Denton, during the Receivership, Debtor never objected to (a) Commonwealth Commercial being engaged to market the Property, (b) the scope, nature, and extent of marketing efforts made by Commonwealth Commercial, or (c) the results of the marketing efforts by Commonwealth Commercial. See the Denton Declaration at paragraph 40. Moreover, the marketing efforts of the Receiver and Commonwealth Commercial were clearly presented to, and approved by the Virginia court, which found that they engaged in and “exhaustive marketing process” in order to sell the Property. Debtors efforts to impugn the marketing efforts to the Receiver and Commonwealth Commercial are without merit and should be rejected. D. The Receiver Has Secured The Property At Great Expense To FourLeaf And Debtor Has No Ability To Maintain The Property, Pay Insurance Or Any Other Costs The appointment of the Receiver was necessary because of Debtor’s inability or unwillingness to properly operate and maintain the Property, pay the underlying debt and property related expenses. The Debtor’s mismanagement resulted in the substantial deterioration of the Property and its value, led to the condemnation of the Property and two separate occassions, and caused the residential tenants to suffer. At the time the Receiver was appointed, Case 25-23251-MEH Doc 18-20 Filed 12/22/25 Entered 12/22/25 20:08:18 Desc Memorandum of Law Page 15 of 20 ANN public copy | complete ECF 18-20 | combined source PDF 470/478
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