This page uses extracted PDF text. Text can misread numbers, dates or table columns. Check the PDF before quoting or interpreting it. Redacted areas remain redacted.
Case 25-23251-MEH Doc 47 Filed 01/05/26 Entered 01/05/26 16:34:06 Desc Main
Document Page 3 of 5
including reviewing documents, consulting experts, and assessing bids—and found no
impropriety before settling on distribution terms for deficiency proceeds. Granting relief will
prevent further estate diminution, enable creditor distributions, and serve efficiency, constituting
“cause” under § 362(d)(1). The lack of equity and reorganization prospects further justify relief
under § 362(d)(2).
5. The Seaview Tenants urge the Court to grant the Bank’s Motion promptly.
II. NOTICE OF FACTS OMITTED BY THE DEBTOR
6. In the interest of transparency and to provide the Court with a complete record for
considering the Bank’s Motion, the Seaview Tenants highlight the following material facts
omitted or inadequately disclosed in the Debtor’s petition, schedules, and statements (as
supported by the Declaration):
a. The Debtor’s pre-petition history of mismanagement, including an incredible 67
misdemeanor citations for fire prevention code violations by Newport News, Virginia’s
Fire Inspection Bureau between April 1, 2020 and November 17, 2022. This and other
mismanagement led to the Property’s condemnation on or about June 29, 2022 and again
or about August 30, 2023 by the City of Newport News.
b. Prosecution by the City of Newport News and the Virginia Supreme Court’s
appointment of a retired judge, Hon. Michelle J. Adkins, on or about September 5, 2024
to oversee the Tenants’ disparate claims, which include unliquidated personal injury and
statutory violations themselves in the millions of dollars against the Debtor and Mr.
Weinstein jointly.
3
ANN PUBLIC COPY - claimant roster and incidental private names redacted; source pagination retained.Jump to an indexed page (35 of 35)