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

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5 8737319.1 Approximately one year after executing the Note, Deed Of Trust and Assignment Of Rents, Debtor caused the Property to fall into a state of disrepair and to be condemned. By way of example, but not limitation, pursuant to a local Virginia media report dated August 1, 2022 (“August 1, 2022 Report”), the Property was condemned for over a month because of serious issues with elevators, flooding on the 15th floor, overheated machine room, and inadequate chillers. The report also indicated that more than a dozen criminal charges were filed related to the Property by the fire marshal’s office and code compliance for failure to maintain the fire detection and alarm system, and that the Property was subject to a fine of $2,500 per day for these violations. By way of example, but not limitation, pursuant to a local Virginia media report dated April 12, 2023 (“April 12, 2023 Report”) the Property failed a recent inspection, and its reopening was in jeopardy. The April 12, 2023 Report recalls the July 1, 2022 condemnation of the Property because of boiler hazards, HVAC issues, nonfunctional egress doors, problems with the fire alarm system and broken elevators, and also notes that the Property was the subject of an emergency shelter operation on behalf of the tenants that were forced to evacuate the Property. The April 12, 2023 Report goes on to note that while the July 2022 condemnation order was lifted, nevertheless residents could not return because the structure failed a recent inspection because units contained trash, there were plumbing and electric code violations, and evidence of water leaks throughout the building. By way of example, but not limitation, pursuant to a local Virginia media report dated July 10, 2023 (July 10, 2023 Report”), just 4 of the Property’s 150 apartments were released for occupancy by the city’s Department Of Code Compliance. The July 10, 2023 Report references Case 25-23251-MEH Doc 18-20 Filed 12/22/25 Entered 12/22/25 20:08:18 Desc Memorandum of Law Page 5 of 20 ANN public copy | complete ECF 18-20 | combined source PDF 460/478
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