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Seaview bankruptcy: tenant response, counsel declaration and deposition excerpts, ECF 47/47-1

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Case 25-23251-MEH Doc 47-1 Filed 01/05/26 Entered 01/05/26 16:34:06 Desc Exhibit 1 - Declaration of Leonard A. Bennett Esq. Page 20 of 30 MIN WEINSTEIN October 27, 2025 vs Benjamin Weinstein Seaview Apartments 28 1 property was worth, and in exchange, you know, we were willing 2 to come up or figure out a way to give them that sum. 3 Q. Did you threaten to file bankruptcy? 4 A. I don't recall doing that. 5 Q. Have you ever filed bankruptcy before? 6 A. No. 7 Q. As of today have you retained bankruptcy counsel? 8 A. No. 9 Q. So if the bank sues you for the additional roughly 10 four million dollars, do you have a plan for dealing with 11 that? 12 A. Not at this time. 13 Q. And are you aware personally of any -- of the 14 negotiations that the Seaview tenants have had with the 15 receivers or through respective counsel? 16 A. My attorney mentioned that there was some 17 conversation, but I am unaware of the details of that. 18 Q. Going back to the beginning where you were asked 19 about insurance, do you know why you didn't have any liability 20 insurance coverage? 21 A. I don't remember the reason for the denial, but I 22 seem to think that the nature of, you know -- the matter did 23 not include anything that warranted their coverage. If I'm 24 not mistaken -- 25 Q. I'm not asking you to answer me on the record, just ESQUIRE DEPOSITION (3376) EsquireSolutions. corn ANN PUBLIC COPY - claimant roster and incidental private names redacted; source pagination retained.
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