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the extraordinary step of getting the Receiver in place and then having fully responsibility to fund
the costs of the receivership and protecting the property.
78.
The Debtor is a SARE with no source of income (which may disqualify it from
SARE status).
79.
The only option here is liquidation, not restructuring, and the Debtor’s CRO
expressly acknowledges that liquidation is the sole option here.
80.
The Property is under contract for what the Property is worth. The buyer engaged
in competitive bidding – lost that bid – then, after default of the winning bidder (Cyclone), was
convinced by the Receiver and Commonwealth Commercial to proceed as backup purchaser for
the Property at the same price of $9,050,000.
81.
The Receivership should be allowed to continue, and the sale of the Property to the
current buyer should be allowed to close.
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Case 25-23251-MEH Doc 18-13 Filed 12/22/25 Entered 12/22/25 20:08:18 Desc
Affidavit Page 15 of 16
ANN public copy | complete ECF 18-13 | combined source PDF 238/478
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