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8.
The Receiver was appointed special receiver by the Virginia Circuit Court on
February 11, 2025.
9.
A true and complete copy of the Order Appointing Special Receiver entered on
February 11, 2025, is attached as Exhibit 2.
Issues Leading to Receivership
10.
The Debtor acquired the Property in or around June, 2021.
11.
After the Debtor acquired and began operating the Property, the City of Newport
News issued a multitude of building code violation notices to the Debtor, all detailed in the
attached Second Amended Complaint (defined below) of the former tenants.
12.
As a result of the Debtor鈥檚 failures to remedy the building code violations to the
City鈥檚 satisfaction, the City first condemned the Property on or around June 28, 2022 (just one
year into its ownership), thereby requiring all of the then tenants to vacate the Property.
13.
I have been informed that those tenants were provided several opportunities to
retrieve personal belongings.
14.
I understand that around mid-May, 2023, after almost a year from the first
condemnation, the City allowed the Debtor to begin to re-tenant the Property. Thereafter, upon
information and belief, the Debtor leased 15 or 16 apartments.
15.
I understand that on or around August 31, 2023, just two months after the resolution
of the first condemnation, a fire erupted in the electrical room at the Property that substantially
damaged the electrical system at the Property. Electrical service was terminated by the damage
caused by that fire, and it remains terminated at the Property. I understand based on information
provided by the Debtor鈥檚 counsel in Virginia that approximately two dozen apartments were leased
at the time of the electrical fire.
Case 25-23251-MEH Doc 18-13 Filed 12/22/25 Entered 12/22/25 20:08:18 Desc
Affidavit Page 3 of 16
ANN public copy | complete ECF 18-13 | combined source PDF 226/478
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