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8737319.1
filing of its bankruptcy petition, Seaview Apartments LLC (“Debtor”) openly and improperly
seeks to circumvent and/or void an Order Approving Amended Motion For Authorization For
Receiver To Sell Property And Granting Motion Seeking Authority To Dispose Of Former
Tenants’ Personal Property (“Order Approving Sale”) properly entered in Case No.
CL2405300T-00 pending in the Circuit Court of the City of Newport News, Virginia (“Virginia
Circuit Court”) on December 3, 2025, in the matter captained FourLeaf Federal Credit Union,
f/k/a Bethpage Federal Credit Union v. Seaview Apartments LLC, a Virginia limited liability
company (“Virginia Receivership Proceeding”), related to the sale of real property with an
address of 2 28th Street (also known as 90 28th Street), Newport News, Virginia (“Property”).
Upon information and belief, the sale of the Property under the Order Approving Sale is
currently scheduled for January 8, 2026.
In support of its bankruptcy petition Debtor submits the Declaration Of David
Goldwasser In Support Of The Debtors’ Chapter 11 Petition, Doc 10 (“Goldwasser
Declaration”). While the Goldwasser Declaration makes sharp but unsupportable allegations
against FourLeaf and the Receiver, submits baseless assertions regarding the marketing and
maximization of the value of the Property, and declares that “a transparent, court-supervised sale
process” is needed, Mr. Goldwasser, incredibly and likely in bad faith, ignores the Order
Approving Sale wherein all that he now seeks related to the “transparency” of the sale process
and the court’s “supervision” is clearly and expressly revealed by the terms of the Order
Approving Sale. By way of example, in the Order Approving Sale the Court expressly found,
among other things, that “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”,
Case 25-23251-MEH Doc 18-20 Filed 12/22/25 Entered 12/22/25 20:08:18 Desc
Memorandum of Law Page 2 of 20
ANN public copy | complete ECF 18-20 | combined source PDF 457/478
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