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prices of $9,300,000 and $9,050,000. The range of four other offers was $2,038,000 to
$7,000,000.
54.
Upon information and belief, the loan from FourLeaf secured by the Property has
a total balance due of approximately $14,000,000. There is no equity in the Property. This
bankruptcy case disserves FourLeaf who is the only creditor whose claim will be paid from the net
sale proceeds of the sale of the Property. FourLeaf could be substantially hurt if it loses the current
buyer and if the Debtor is unable to secure a buyer at the same or a higher price.
55.
It would take months to complete a new round of marketing. Beyond that, it could
take an interested party 60 days or more to understand the unique risks and issues at this Property
and identify and price solutions.
56.
The potential upside of remarketing the Property as the Debtor proposes is wholly
speculative and uncertain, yet the risks of remarketing would be completely borne by FourLeaf.
57.
It would be one thing if the Debtor were able to present now an alternative buyer at
a materially greater price who is ready, willing, and able to close by mid-January, 2026, but it has
not done so.
58.
The sole party identified by the Debtor as a possible buyer was Cyclone, and
Cyclone鈥檚 ultimate offer of $9,300,000 (which failed as a result of defaults by Cyclone under the
applicable purchase agreement) is not materially higher than the $9,050,000 purchase price in the
Receiver鈥檚 agreement with the current buyer for the Property.
59.
The current buyer is poised to close within three weeks at a hard fought price
acceptable to the Receiver and FourLeaf. The price is substantially less than the secured
indebtedness, leaving nothing for other creditors or the Debtor.
Case 25-23251-MEH Doc 18-13 Filed 12/22/25 Entered 12/22/25 20:08:18 Desc
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