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38.
The Property was aggressively marketed by Commonwealth Commercial. It was
listed on LoopNet, Crexi and CoStar, which are national listing services used by most commercial
real estate investors and brokers in the United States (and by international investors seeking
property in the United States). The listings generating tens of thousands of impressions across the
various platforms, and more than 10,000 direct engagements. More than 1,900 users viewed the
property specific details and offering information. Forty non-disclosure agreements were
executed, 42 individuals signed access waivers and toured the Property, and five offers were
received.
39.
Of the 40 parties who signed non-disclosure agreements, the Receiver can identify
addresses for 35 parties. Of those 35 parties, 19 were from Virginia (which is expected given the
Property’s location), five from New York, three from New Jersey, two from Washington, D.C.,
and one each from Illinois, Delaware, Texas, North Carolina, Florida, and Maryland.
40.
At no time during the receivership did the Debtor directly or through its Virginia
counsel object to (a) Commonwealth Commercial being engaged to market the Property, (b) the
scope, nature, and extent of marketing efforts made by Commonwealth Commercial, or (c) the
results of the marketing efforts by Commonwealth Commercial.
41.
One of the parties who signed a non-disclosure agreement was Cyclone Investment
Group, LLC (“Cyclone”) out of Valley Stream, New York. Prior to the Receiver marketing the
property, Cyclone contacted the Receiver and made an unsolicited, preemptive bid of $5,500,000.
At the time Cyclone was advised the Property would be marketed for competitive bids before the
Receiver would entertain offers. I believe Cyclone was referred to Commonwealth Commercial
by the principal of 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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