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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 3 of 30
1994, I have appeared in approximately 1,300 cases in the Eastern District of Virginia, as well as
numerous cases nationwide. I am widely recognized for my experience and leadership in consumer
rights litigation, including housing and landlord-tenant matters.
3. In my capacity as counsel for the Seaview Tenants in pending Virginia litigation, I
am familiar with the operations and history of Seaview Apartments, LLC (“Seaview”) and its
principal, Benjamin Weinstein.
4. Seaview Apartments, LLC is a Virginia limited liability company that Mr.
Weinstein created as a shell entity to own and operate the Seaview apartment building. Weinstein
Dep. Transcript at 91:15-23, 92:6-11. Mr. Weinstein exercised complete personal control over all
aspects of Seaview’s business – he made all management decisions, controlled all finances,
directed maintenance, dealt with contractors and city officials, set all leasing policies, and decided
which repairs to perform or ignore. Id., 92:6-11, 96:23-97:21. In effect, Seaview Apartments, LLC
had no independent functioning separate from Mr. Weinstein, who acted as the de facto owner and
manager of the property. Id.
5. From the outset, Seaview Apartments, LLC was financially unstable and lacked
sufficient capitalization. Id. at 96:23-97:21. The company’s sole substantial asset was (and is) the
Seaview apartment building itself. Id. at 91:15-23. Seaview had virtually no capital reserves or
separate funds of its own. Id. at 96:23-97:16. All operational expenses for Seaview – including
maintenance costs and even legal fees to defend lawsuits – had to be paid by Mr. Weinstein
personally, because the LLC lacked assets or income of its own. Id.
6. These facts demonstrated that Seaview was a hollow corporate shell dominated by
Mr. Weinstein.
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