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8737319.1
Lender Pursuant To 11 U.S.C. §543(d) And Providing State Court Receiver With Limited
Excuse From Provisions Of 11 U.S.C. §543(a) And (b); And Granting Related Relief (“Foushee
Declaration”) and the Declaration Of Edward Denton (“Denton Declaration”).
BACKGROUND
A. FourLeaf’s Loan To Debtor
Debtor is indebted to FourLeaf pursuant to a certain Note dated June 4, 2021, executed
by Debtor, as maker, and payable to FourLeaf, as payee, in the original principal amount of
$12,000,000 (“Note”). The Note evidences a commercial real estate loan (“Loan”) made by
FourLeaf to Debtor. The proceeds of the funds advanced under the Note were used in
connection with the Property.
Repayment of the Note is secured by, among other things, the liens, security interests,
terms and provisions contained within that certain Deed of Trust dated June 4, 2021, executed
and delivered by Debtor, for the benefit of FourLeaf, as beneficiary, recorded as Instrument
Number 210012223 in the Real Property Records of Newport News, Virginia on June 7, 2021
(“Deed Of Trust”). The Note is also secured by an Assignment of Rents dated June 4, 2021,
executed and delivered by Debtor, as assignor, to FourLeaf, as assignee, recorded as Instrument
Number 210012224 in the Real Property Records of Newport News, Virginia (“Assignment Of
Rents”).
The total amount due on the Note, as of December 22, 2025, is $14,748,464.03.
B. Debtor Causes Property To Fall Into State Of Disrepair And To Be Condemned
Case 25-23251-MEH Doc 18-20 Filed 12/22/25 Entered 12/22/25 20:08:18 Desc
Memorandum of Law Page 4 of 20
ANN public copy | complete ECF 18-20 | combined source PDF 459/478
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