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8737319.1
Debtor’s late effort to obtain hazard insurance for the Property is developing as of the
writing of this application. In the afternoon of December 22, 2025, counsel for FourLeaf
reviewed a copy of an Acord 27 Evidence Of Property Insurance indicating that Debtor obtained
hazard insurance for the Property under a policy of insurance issued by Mt Hawley Insurance
Co. bearing policy number SUBID3832543, with an effective date of December 18, 2025 to
December 18, 2026, in the amount of $10,000,000.00 (“Mt Hawley Policy”). The U.S. Trustee is
named as an Additional Interest. It is unclear what information the Debtor provided to the
insurance carrier to obtain the Mt Hawley Policy. Additionally, a copy of the Mt Hawley Policy
has not been provided.
Issues related to insurance of the Property can be eliminated upon the closing of the sale
of the Property on January 8, 2026. Excusing FourLeaf and Receiver from the provisions of 11
U.S.C. §543(a) and (b) will prevent the return of the Property to Debtor and the lapsing of the
liability coverage for the Property.
F. A Settlement Has Been Reached With The Tenants Of The Property
The suffering of the former tenants of the Property is well documented and known
throughout the Newport News community as demonstrated through local media reports. See the
Foushee Declaration at Exhibits “D” through “G.” The Judge that presided over the Virginia
Receivership Proceeding expressed concerns related to how the former tenants were treated and
it was understood that some accommodation of the former tenants would be required for the
Virginia court to enter to Order Approving Sale.
FourLeaf and a group of former tenants reached such an accommodation through a
written settlement agreement. This settlement agreement was also approved under the Order
Case 25-23251-MEH Doc 18-20 Filed 12/22/25 Entered 12/22/25 20:08:18 Desc
Memorandum of Law Page 17 of 20
ANN public copy | complete ECF 18-20 | combined source PDF 472/478
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