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Case 25-23251-MEH Doc 47 Filed 01/05/26 Entered 01/05/26 16:34:06 Desc Main
Document Page 1 of 5
UNITED STATES BANKRUPTCY COURT
DISTRICT OF NEW JERSEY
Caption in Compliance with D.N.J. LBR 9004-1(b)
CONSUMER LITIGATION ASSOCIATES LAW OFFICES OF KENNETH L. BAUM,
Leonard A. Bennett (pro hac vice forthcoming) LLC
763 J. Clyde Morris Boulevard Kenneth L. Baum (NJ Bar No. 043191993)
Suite 1-A 201 W. Passaic St., Suite 104
Newport News, VA 23601 Rochelle Park, New Jersey 07662
Tel: (757) 930-3660 Tel: (201) 853-3030
Email: lenbennett@clalegal.com Email: kbaum@kenbaumdebtsolutions.com
Lead Counsel to Local Counsel to
the Seaview Tenant Claimants the Seaview Tenant Claimants
In re: Case No. 25-23251 (MEH)
SEAVIEW APARTMENTS LLC, Chapter 11
Debtor-in-Possession Honorable Mark E. Hall, U.S.B.J.
SEAVIEW TENANT CLAIMANTS’ RESPONSE IN SUPPORT OF
CREDITOR FOURLEAF FEDERAL CREDIT UNION’S
MOTION FOR RELIEF FROM AUTOMATIC STAY
The 94 tenants identified in Exhibit A to the concurrently filed Application for
Admission Pro Hac Vice (collectively, the “Seaview Tenants”), by and through their
undersigned counsel, hereby file this Response in Support of Fourleaf Federal Credit Union’s
Motion for Relief from the Automatic Stay of 11 U.S.C. § 362(a) (the “Bank’s Motion”) [Docket
No. 26] with respect to real property known as Seaview Loft Apartments, A/K/A Oceanside
Tower, located at 2 28th Street, Newport News, Virginia. The Seaview Tenants also include
herein a Notice of Facts Omitted by the Debtor in Its Filings, and a Preview of Intent to File a
Motion to Dismiss the Chapter 11 Case for Bad Faith (this “Joinder and Notice”). This filing is
supported by the Declaration of Leonard A. Bennett, Esquire (the “Declaration”), attached hereto
as Exhibit 1. In support thereof, the Seaview Tenants respectfully state as follows:
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