This page uses extracted PDF text. Text can misread numbers, dates or table columns. Check the PDF before quoting or interpreting it. Redacted areas remain redacted.
10
聽
46.
FourLeaf approved of this sale at this price, and the Receiver entered into a
purchase agreement with the current buyer.
47.
At no time during the receivership did the Debtor directly or through its Virginia
counsel object to the purchase agreement with the current buyer or the sale price to the current
buyer.
48.
FourLeaf filed a motion to approve the sale of the Property to the current buyer.
That motion and a notice of hearing were served on the Debtor through its Virginia counsel.
Counsel for the Debtor attended the hearing before the Virginia Circuit Court on FourLeaf鈥檚
motion to approve. At that hearing, the Debtor did not voice any objections of any sort to the
current buyer, the terms of sale, or the $9,050,000 price. The Debtor presented no evidence or
witnesses in opposition to this motion, and it made no arguments in opposition to the motion.
49.
The Virginia Circuit Court entered an order approving the sale to the current buyer
on December 3, 2025. I have attached a true and complete copy of that order as Exhibit 5.
Current Purchase Agreement may be at Risk
50.
The closing of the sale of the Property to the current buyer was scheduled for
January 8, 2026.
51.
As a result of the stay in this bankruptcy case, that closing cannot occur. This
bankruptcy case prevents satisfaction of conditions precedent to the closing; therefore, this
bankruptcy case has put the sale to the current buyer at risk.
52.
It is imperative that the sale to the current buyer close.
53.
The Debtor鈥檚 CRO has taken the position that somehow he can produce a sale of
the Property at a price well in excess of $9,050,000. That obviously is pure speculation and
perhaps fantasy. The best evidence of value of the Property is the two purchase agreements with
Case 25-23251-MEH Doc 18-13 Filed 12/22/25 Entered 12/22/25 20:08:18 Desc
Affidavit Page 10 of 16
ANN public copy | complete ECF 18-13 | combined source PDF 233/478
Jump to an indexed page (16 of 16)