bankruptcy auction tuesday, june 20, 2017 at...

100%StockSaleof SeCarAutoWash,Inc.

3009AnnandaleRoad,FallsChurch,Virginia22042

BANKRUPTCYAUCTIONTuesday,June20,2017at9:30am

OnbehalfofaChapter7Trustee,weareofferingforsale,subjecttothetermsoftheSaleMotionpendingbeforetheUSBankruptcyCourt,100%ofthestockownershipinavaluablefullservicecarwashlocatedabouttwomilesinsidetheBeltwayneartheintersectionofRt.50andAnnandaleRoadinFallsChurch,Virginia.Thisofferingincludestherealestate,equipmentandbusinessassetsbelongingtoSeCarAutoWash,Inc(“SeCar”).ThecurrentofferpendingbeforetheBankruptcyCourtisforthepurchaseof100%ofthestockinSeCarfor$375,000,subjecttotheexistingmortgageandliabilitiesofthecompanytotalingapproximately$3,800,000+/-.AprospectivebuyercansubmitahigherandbetterofferforthestockbysubmittingacompetingwrittenoffertotheTrusteeandStephenKarbelkbyThursday,June15,2017at5:00pm,subjecttothedetailedrequirementsintheTRUSTEE’SNOTICEOFINTENTIONTOSELLPROPERTYOFTHEESTATEBACKTOTHEDEBTOR,NOTICEOFHEARINGONMOTIONANDNOTICEOFOPPORTUNITYTOOBJECTORMAKEHIGHERBID(the“SaleMotion”)(Doc348)filedwiththeUSBankruptcyCourt,EasternDistrictofVirginia,AlexandriaDivision.EachbuyershallalsoberequiredtoattendtheBankruptcyCourtsalehearingonTuesday,June20,2017at9:30amlocatedattheUSBankruptcyCourt,CourtroomIII,200S.WashingtonStreet,Alexandria,VA22314.PleaserefertotheSaleMotionfordetails.Giventhecomplexitiesofthisparticulartransaction,prospectivebuyersareencouraged,butnotrequired,toberepresentedbycounselpriortosubmittinganofferandparticipatinginthesalehearingprocess.Nobrokeragecommissionisofferedtocooperatingbrokersforastocksaletransaction.AllsalesaresubjecttoUSBankruptcyCourtapproval.ContactRealtyMarketstoobtainaConfidentialityAgreementtoseetheavailablefinancials.

Pleasevisitwww.RealtyMarkets.comforthetermsandconditions.

Formoreinformation,pleasecontactStephenKarbelkat571-481-1037orStephanieYoungat571-223-9775orstephanie@realtymarkets.com.

ConfidentialityAgreement

Pleasesignandreturntogainaccesstotheavailableduediligenceinformation.

In order to receive the Property Information Package(s), please neatly complete the following agreement and return it to Stephanie

Young at (866) 248-7066 (fax) or email to [email protected]

CONFIDENTIALITY AGREEMENT

THIS CONFIDENTIALITY AGREEMENT (the “Agreement”) is made and entered into as of the date hereinafter set forth by Kevin R. McCarthy, Trustee (herein, “Seller”) and the person(s) designated as the Reviewer on the signature page hereof (the “Reviewer”).

WHEREAS, the Seller, subject to TRUSTEE’S NOTICE OF INTENTION TO SELL PROPERTY OF THE ESTATE BACK TO THE DEBTOR, NOTICE OF HEARING ON MOTION AND NOTICE OF OPPORTUNITY TO OBJECT OR MAKE HIGHER BID IN RE: KYEUNG GUK MIN, CASE NO. 14-13416-BFK, is soliciting bidders to purchase 100% of the stock in SeCar Auto Wash, Inc., an entity that owns the real estate, personal property and intangible assets more particularly located at 3009 Annandale Road, Falls Church, Virginia 22042 (the “Property”); and

WHEREAS, the Reviewer has requested information about the Property; and

WHEREAS, as a condition to furnishing the Reviewer with such requested information, Seller requires that the Reviewer agree to treat such information as confidential as set forth in detail below.

In consideration of the foregoing, the mutual promises hereinafter set forth and other good and valuable consideration, the receipt and sufficiency of which are hereby acknowledged, the parties hereto, intending to be legally bound, agree as follows:

1. All information furnished by Seller or any of his representatives or agents (collectively, the “Confidential Information”) to the Reviewer or its directors, officers or employees, or outside attorneys, accountants or financial advisors (collectively, “Representatives”) shall not be used for any purpose that is without consent by Seller. The term “Confidential Information” shall be deemed also to include all cash flow information, analyses, compilations, modeling, studies or other documents prepared by the Reviewer or its representatives containing or based in whole or in part on any information furnished by Seller or any of its representatives or agents. Confidential Information may be disclosed only to those who sign their own confidentiality agreement furnished by the Reviewer, and who in the Reviewer’s considered judgment, need to know such information for the purpose of marketing the Property. The Reviewer shall direct all of its representatives to keep all such information in the strictest confidence. Any disclosure by a representative shall be deemed made by, and be the responsibility of, the Reviewer.

2. In addition, without the prior written consent of the Seller, the Reviewer will

not, and will direct any of his representatives or agents not to, disclose to any person (a) that the Confidential Information has been made available to you or your representatives or agents, (b) that discussions are taking place concerning the Property, or (c) any terms or other facts with respect to the Property including the status thereof.

3. The Reviewer agrees not to communicate with any borrower, guarantor, indemnitor, or the accountant, attorney or representative of any of them, or their banks, investors, sources of funds or other entities relative to the Property, unless written permission has been obtained from the Seller.

4. In the event that the Reviewer or its representatives is requested or become

legally compelled to disclose any of the Confidential Information or the fact that the Confidential Information has been made available to the Reviewer or that discussions or negotiations between the Reviewer and Seller are taking place, the Reviewer agrees to provide Seller with prompt written notice of such request so that Seller may seek a protective order or other appropriate remedy or waive compliance with the provisions of this Agreement.

5. Upon the request of Seller, the Reviewer shall promptly deliver to Seller all Confidential Information furnished to the Reviewer, whether furnished before or after the date of this Agreement, without retaining copies thereof. The Reviewer shall destroy any compilations, studies, notes or other documents or records which contain or reflect Confidential Information relating to the Property. The obligations of confidentiality and secrecy contained in this Agreement shall continue to apply to the Reviewer and its Representatives and be binding and enforceable upon the Reviewer and its Representatives following the return to Seller of the Confidential Information.

6. It is understood and agreed that money damages may not be a sufficient remedy for any breach of this agreement, and that Seller shall be entitled to equitable relief, including specific performance injunctive relief, in the event of any breach of the provisions of this Agreement, in addition to all other remedies available at law or in equity. If litigation should be necessary to enforce this Agreement, Seller shall be entitled to recover from the Reviewer all costs of such litigation, including reasonable attorneys’ fees, in addition to any other relief to which it is entitled.

7. The Reviewer shall indemnify and hold harmless Seller and his agents, representatives, attorneys and accountant(s) against any and all claims, damages, losses, liability or expenses, including reasonable attorneys’ fees that may result as a breach of this Agreement by the Reviewer, or its officers, directors, employees or representatives.

8. This Agreement shall be governed by, and construed in accordance with, the laws of the Commonwealth of Virginia. In the event of a dispute that may arise under this Agreement, the Reviewer consents to the exclusive jurisdiction of the US Bankruptcy Court, Eastern District of Virginia, Alexandria Division, Case No. 14-13416-BFK.

9. Non-Solicitation of Customers, Customer Prospects, Employees and Vendors. The Reviewer acknowledges that they may have access to confidential information about the Seller’s operations, including employee compensation and customer bookings. The Reviewer covenants and agrees that from the date of this Agreement until December 31, 2017 that the Reviewer will not, directly or indirectly, solicit or attempt to solicit any business from any of the Seller’s Customers, Customer Prospects, Employees or Vendors. If the Reviewer is independently contacted by a Customer, Customer Prospect or Employee at any time before December 31, 2017, the Reviewer will notify within 24 hours of the contact via email Stephen Karbelk, agent for the Seller, at [email protected]. The Seller understands that unsolicited contact may occur, and the Reviewer will not be held liable for such an activity, but the Reviewer agrees to notify the Seller’s attorney within 24 hours of the contact via email in the event it does occur.

10. MOST OF THE INFORMATION PROVIDED TO THE REVIEWER HAS BEEN PROVIDED BY THE SELLER TO THE BROKER AND HAS NOT BEEN INDEPENDENTLY VERIFIED BY THE BROKER. THE BROKER SELLER MAKES NO REPRESENTATION THAT THE INFORMATION PROVIDED IS COMPLETE OR ACCURATE AND SPECIFICALLY DISCLAIMS ANY WARRANTIES, EXPRESS OR IMPLIED, RELATING TO THE PROPERTY. THE REVIEWER IS SOLELY RESPONSIBLE FOR CONDUCTING ITS OWN INVESTIGATIONS, INSPECTIONS AND DUE DILIGENCE TO DETERMINE THE CONDITION OF THE PROPERTY AND ITS FITNESS AND SUITABILITY FOR A PARTICULAR PURPOSE PRIOR TO SUBMITTING ANY OFFER FOR THE PURCHASE OF ANY PROPERTY.

11. ALL PROPERTY IS OFFERED FOR SALE ON AN “AS-IS”, “WHERE IS”, AND “WITH ALL FAULTS” BASIS. THE SELLER DOES NOT AND WILL NOT MAKE ANY EXPRESS OR IMPLIED WARRANTY, GUARANTY, OR REPRESENTATION CONCERNING ANY OF THE INFORMATION INCLUDED IN THE PROPERTY INFORMATION PACKAGES OR PROVIDED BY ANY AGENT OR BROKER OR OTHERWISE RELATED TO THE PROPERTY. ANY PROJECTIONS, OPINIONS, OR ASSUMPTIONS THAT MAY BE MADE BY SELLER, ITS AGENTS OR AFFILIATES REGARDING THE PROPERTY SHALL NOT BE RELIED UPON BY THE REVIEWER.

Signatures Begin on the Following Page

IN WITNESS WHEREOF, this Agreement has been executed effective as of , 2017.

REVIEWER: Entity:

, a

By: Name: Title:

OR

Individual:

Printed Name:

Primary Contact Information:

Address

City, State, Zip

Email

Phone

Fax

PLEASE NEATLY COMPLETE ALL CONTACT INFORMATION REQUESTED ABOVE. THE DUE DILIGENCE INFORMATION WILL BE PROVIDED VIA A

DROPBOX LINK ONLY. PRINTED COPIES ARE NOT AVAILABLE.

SaleMotion

ThefollowingSaleMotiondetailsthecurrentofferandtheproceduresforsubmittingahigherandbetterbid.

Kevin R. McCarthy, VSB No. 14273 McCarthy & White, PLLC 1751 Pinnacle Drive, Suite 1115 McLean, VA 22102 703-770-9261 [email protected] Attorneys for Trustee

UNITED STATES BANKRUPTCY COURT FOR THE EASTERN DISTRICT OF VIRGINIA

Alexandria Division

************************************* In re: * * KYEUNG GUK MIN * Case No. 14-13416-BFK * (Chapter 7) Debtor(s). * *************************************

TRUSTEE’S MOTION TO SELL PROPERTY OF THE ESTATE BACK TO THE DEBTOR

Kevin R. McCarthy, Trustee moves the Court for authorization to sell personal property

of the estate back to the Debtor pursuant to 11 U.S.C. § 363(b) and Federal Rule of Bankruptcy

Procedure 6004(a)-(b) on the terms and conditions set forth in his Notice Of Intention To Sell

Property Of The Estate Back to the Debtor filed simultaneously with this Motion, and to take any

actions provided therein without further Order of the Court, namely:

PROPERTY FOR SALE: Debtor's 100% of the issued and outstanding stock for SeCar Auto Wash, Inc., a Subchapter S corporation that owns the real estate and on-going business operations of a car wash located at 3009 Annandale Road, Falls Church, Virginia (“ the Stock”). TYPE OF SALE: Private. PRIVATE SALE PRICE: $375,000. The Asset Purchase Agreement is attached as Exhibit A to the Motion. BUYER: Kyeung Guk Min, the Debtor. APPRAISAL VALUE: The underlying assets of SeCar Auto Wash, Inc. have been appraised as follows: a) the real estate was appraised at a value of $1,340,000 in October 2014 (not including mortgage debt of about $2,500,000); and b) the car wash business was appraised at a value of $971,700 in June 2014 (not including a potential surety bond indemnification obligation in excess of $1,000,000). The Trustee's sales agent advises that the proposed stock price is reasonable under the circumstances. He will market the Stock until June 15, 2017 to investors who may be interested in owning a car wash business. Although the sale is structured as a stock sale, potential investors may be interested in purchasing the underlying assets instead of stock, and the Trustee's sales agent will analyze any such offers for equivalency with the proposed stock price.

Case 14-13416-BFK Doc 347 Filed 05/10/17 Entered 05/10/17 15:29:41 Desc Main Document Page 1 of 2

SALES AGENT: Stephen Karbelk and Century 21 New Millennium. COMPENSATION TO SALES AGENT: Two (2%) percent of the gross sale proceeds, or $10,000, whichever is greater, if the sale is back to the Debtor; six (6%) percent of the gross sale proceeds if the sale is to a third party. TIME AND PLACE OF SALE: 15th day after Court approval. Place of sale to be determined. As a practical matter, no closing will be necessary if the Stock is sold back to the Debtor because the Stock is already owned by the Debtor. LIENS: None. DEBTOR'S EXEMPTIONS: None. TAX CONSEQUENCES TO ESTATE BY SALE: The Trustee estimates that the estate will incur federal and state incomes taxes of approximately $32,000. The Debtor's stock basis is about $160,000, and as a result the estate will have long-term capital gain of about $215,000. NET SALE PROCEEDS ESTIMATED TO BE PAID TO ESTATE: $365,000 net of sale costs (excluding trustee compensation and legal fees, which will be applied for at a later date, and excluding federal and state income taxes). APPLICABILITY OF 11 USC § 363(m) AND FEDERAL RULE OF BANKRUPTCY PROCEDURE 6004(h). Entry of an Order granting the Trustee’s Motion will constitute a Court determination that the Debtor is a good faith purchaser and that the Order be immediately effective. Wherefore, the Trustee requests the Court to enter the attached proposed Order. Respectfully submitted, /s/ Kevin R. McCarthy Kevin R. McCarthy, VSB No. 14273 McCarthy & White, PLLC 1751 Pinnacle Drive – Suite 1115 McLean, VA 22102 (703) 770-9261 [email protected] Attorneys for Trustee

CERTIFICATE OF SERVICE

I hereby certify that on the 10th day of May, 2017 I served a copy of the foregoing, including the attached proposed Order, through the court’s ecf system on all registered ecf participants who have appeared in this case. /s/ Kevin R. McCarthy Kevin R. McCarthy




Alexandria Division


ORDER GRANTING TRUSTEE’S MOTION TO SELL PROPERTY OF THE ESTATE BACK TO THE DEBTOR

Upon Consideration of the Trustee’s Motion To Sell Property Of The Estate Back To

The Debtor (“Motion”), and any response, it is

ORDERED, that the Motion be, and hereby is, GRANTED, and the Trustee is authorized

to sell personal property of the estate back to the Debtor pursuant to 11 U.S.C. § 363(b) and

Federal Rule of Bankruptcy Procedure 6004(a)-(b) on the terms and conditions set forth in his

Notice Of Intention To Sell Property Of The Estate Back To The Debtor filed simultaneously

with the Motion, and to take any actions provided therein without further Order of the Court,

namely:

PROPERTY FOR SALE: Debtor's 100% of the issued and outstanding stock for SeCar Auto Wash, Inc., a Subchapter S corporation that owns the real estate and on-going business operations of a car wash located at 3009 Annandale Road, Falls Church, Virginia (“ the Stock”). TYPE OF SALE: Private. PRIVATE SALE PRICE: $375,000. The Asset Purchase Agreement is attached as Exhibit A to the Motion. BUYER: Kyeung Guk Min, the Debtor. APPRAISAL VALUE: The underlying assets of SeCar Auto Wash, Inc. have been appraised as follows: a) the real estate was appraised at a value of $1,340,000 in October 2014 (not

Case 14-13416-BFK Doc 347-2 Filed 05/10/17 Entered 05/10/17 15:29:41 Desc Proposed Order Page 1 of 3

2

including mortgage debt of about $2,500,000); and b) the car wash business was appraised at a value of $971,700 in June 2014 (not including a potential surety bond indemnification obligation in excess of $1,000,000). The Trustee's sales agent advises that the proposed stock price is reasonable under the circumstances. He will market the Stock until June 15, 2017 to investors who may be interested in owning a car wash business. Although the sale is structured as a stock sale, potential investors may be interested in purchasing the underlying assets instead of stock, and the Trustee's sales agent will analyze any such offers for equivalency with the proposed stock price. SALES AGENT: Stephen Karbelk and Century 21 New Millennium. COMPENSATION TO SALES AGENT: Two (2%) percent of the gross sale proceeds, or $10,000, whichever is greater, if the sale is back to the Debtor; six (6%) percent of the gross sale proceeds if the sale is to a third party. TIME AND PLACE OF SALE: 15th day after Court approval. Place of sale to be determined. As a practical matter, no closing will be necessary if the Stock is sold back to the Debtor because the Stock is already owned by the Debtor. LIENS: None. DEBTOR'S EXEMPTIONS: None. TAX CONSEQUENCES TO ESTATE BY SALE: The Trustee estimates that the estate will incur federal and state incomes taxes of approximately $32,000. The Debtor's stock basis is about $160,000, and as a result the estate will have long-term capital gain of about $215,000. NET SALE PROCEEDS ESTIMATED TO BE PAID TO ESTATE: $365,000 net of sale costs (excluding trustee compensation and legal fees, which will be applied for at a later date, and excluding federal and state income taxes). APPLICABILITY OF 11 USC § 363(m) AND FEDERAL RULE OF BANKRUPTCY PROCEDURE 6004(h). Entry of an Order granting the Trustee’s Motion will constitute a Court determination that the Debtor is a good faith purchaser and that the Order be immediately effective. IT IS FURTHER ORDERED, that the Asset Purchase Agreement attached to the Motion

as Exhibit A is APPROVED, and the Trustee is authorized to pay his Sales Agent fees

as provided above in his Notice Of Intention To Sell Property Of The Estate Back To The

Debtor.

Date: Brian F. Kenney U.S. Bankruptcy Judge


3

I ask for this: /s/ Kevin R. McCarthy Kevin R. McCarthy, VSB No. 14273 McCarthy & White, PLLC 1751 Pinnacle Drive – Suite 1115 McLean, VA 22102 703-770-9261 [email protected] Attorneys for Trustee

Local Rule 9022-1(C) Certification

The foregoing Order was endorsed by all necessary parties or served upon all necessary parties as indicated in the Certificate of Service attached to the Motion, pursuant to Local Rule 9022-1(C). /s/ Kevin R. McCarthy Kevin R. McCarthy PARTIES TO RECEIVE COPIES all registered ECF participants who have appeared in this case


Case 14-13416-BFK Doc 347-1 Filed 05/10/17 Entered 05/10/17 15:29:41 Desc Exhibit A Page 1 of 3



Alexandria Division


TRUSTEE’S NOTICE OF INTENTION TO SELL PROPERTY OF THE ESTATE BACK TO THE DEBTOR, NOTICE OF HEARING ON MOTION,

AND NOTICE OF OPPORTUNITY TO OBJECT OR MAKE HIGHER BID

PLEASE TAKE NOTICE that Kevin R. McCarthy, Trustee has filed a Motion and intends to sell personal property of the estate back to the Debtor pursuant to 11 U.S.C. § 363(b) and Federal Rule of Bankruptcy Procedure 6004(a)-(b) as follows, subject to Court approval: PROPERTY FOR SALE: Debtor's 100% of the issued and outstanding stock for SeCar Auto Wash, Inc., a Subchapter S corporation that owns the real estate and on-going business operations of a car wash located at 3009 Annandale Road, Falls Church, Virginia (“ the Stock”). TYPE OF SALE: Private. PRIVATE SALE PRICE: $375,000. The Asset Purchase Agreement is attached as Exhibit A to the Motion. BUYER: Kyeung Guk Min, the Debtor. APPRAISAL VALUE: The underlying assets of SeCar Auto Wash, Inc. have been appraised as follows: a) the real estate was appraised at a value of $1,340,000 in October 2014 (not including mortgage debt of about $2,500,000); and b) the car wash business was appraised at a value of $971,700 in June 2014 (not including a potential surety bond indemnification obligation in excess of $1,000,000). The Trustee's sales agent advises that the proposed stock price is reasonable under the circumstances. He will market the Stock until June 15, 2017 to investors who may be interested in owning a car wash business. Although the sale is structured as a stock sale, potential investors may be interested in purchasing the underlying assets instead of stock, and the Trustee's sales agent will analyze any such offers for equivalency with the proposed stock price. SALES AGENT: Stephen Karbelk and Century 21 New Millennium. COMPENSATION TO SALES AGENT: Two (2%) percent of the gross sale proceeds, or $10,000, whichever is greater, if the sale is back to the Debtor; six (6%) percent of the gross


sale proceeds if the sale is to a third party. TIME AND PLACE OF SALE: 15th day after Court approval. Place of sale to be determined. As a practical matter, no closing will be necessary if the Stock is sold back to the Debtor because the Stock is already owned by the Debtor. LIENS: None. DEBTOR'S EXEMPTIONS: None. TAX CONSEQUENCES TO ESTATE BY SALE: The Trustee estimates that the estate will incur federal and state incomes taxes of approximately $32,000. The Debtor's stock basis is about $160,000, and as a result the estate will have long-term capital gain of about $215,000. NET SALE PROCEEDS ESTIMATED TO BE PAID TO ESTATE: $365,000 net of sale costs (excluding trustee compensation and legal fees, which will be applied for at a later date, and excluding federal and state income taxes). APPLICABILITY OF 11 USC § 363(m) AND FEDERAL RULE OF BANKRUPTCY PROCEDURE 6004(h). Entry of an Order granting the Trustee’s Motion will constitute a Court determination that the Debtor is a good faith purchaser and that the Order be immediately effective. HEARING: A hearing shall be held on the Trustee’s Motion at 9:30 a.m. on June 20, 2017 in Courtroom III of the U.S. Bankruptcy Court, which is located at 200 S. Washington Street, Alexandria, VA 22314-5405. YOUR RIGHTS MAY BE AFFECTED. You should read these papers carefully and discuss them with your attorney, if you have one in this bankruptcy case. (If you do not have an attorney, you may wish to consult one.) OPPORTUNITY TO OBJECT OR MAKE HIGHER BID: If you do not wish the court to grant the relief sought in the Motion, or if you want the court to consider your views on the Motion, OR IF YOU WISH TO MAKE A HIGHER BID, then ON OR BEFORE 5:00 P.M. ON JUNE 15, 2017 you or your attorney must do the following checked items: X File with the court, at the address shown below, a written response with supporting memorandum as required by Local Bankruptcy Rule 9013-1(H). Unless a written response and supporting memorandum are filed and served by the date specified, the Court may deem any opposition waived, treat the Motion as conceded, and issue an order granting the requested relief without further notice or hearing. If you mail your response to the court for filing, you must mail it early enough so the court will receive it on or before the date stated above. The address for the court is as follows: Clerk of the Court United States Bankruptcy Court 200 South Washington Street Alexandria, Virginia 22314 X If you wish to make a higher bid, subject to Court approval the following procedures shall apply:

Any bidder for the Stock must submit a competing written offer to the Trustee at [email protected] and his Sales Agent at [email protected] that is at least $5,000 more than the proposed sale price to the Debtor by Thursday, June 15, 2017 at 5:00 p.m.


Any bidder represents that he has read and understands the Asset Purchase Agreement (a copy of which will be provided upon request to the Sales Agent or the Trustee). Any bidder represents that he is in agreement with all terms of the Asset Purchase Agreement other than sale price and purchaser. Any bidder represents that he has no other conditions or contingencies of sale except those provided for in the Asset Purchase Agreement. Any bidder may contact the Trustee’s Sales Agent for available financial information subject to execution of the Trustee’s Confidentiality Agreement. Any bidder represents that he has the financial ability to close on the transaction as provided in the Asset Purchase Agreement, and shall provide supporting documentation satisfactory to the Trustee upon request. Any bidder must have a $10,000 certified or cashier's check at the sale hearing payable to the Trustee, or payable to himself and endorsable to the Trustee, if he is the winning bidder. Any bidder represents that he intends to participate in the sale hearing. A bidder may bid either in person or through counsel, or by phone if permitted by the Court. If a bidder submits a bid for the underlying assets of SeCar Auto Wash, Inc. instead of the Stock, the bid must be for an amount that will return at least $25,000 more to the estate than the proposed sale price of the Stock to the Debtor. Any losing bidder shall have the option to be a binding back-up bid if the winning bidder defaults. The Trustee reserves the right to approve each bidder prior to allowing him to bid at the sale hearing.

X Unless the Motion is granted beforehand, you must also attend the hearing on the Motion scheduled to be held on June 20, 2017 a.m. in Courtroom III of the U.S. Bankruptcy Court, which is located at 200 S. Washington Street, Alexandria, VA 22314-5405. If you or your attorney do not take these steps, the court may decide that you do not oppose the relief sought in the Motion and may enter an order granting that relief. Date of Mailing: 5/10/17 Respectfully submitted, /s/ Kevin R. McCarthy Kevin R. McCarthy, VSB No. 14273 McCarthy & White, PLLC 1751 Pinnacle Drive – Suite 1115 McLean, VA 22102 (703) 770-9261 [email protected] Attorneys for Trustee


CERTIFICATE OF SERVICE

I hereby certify that on the 10th day of May, 2017 I served a copy of the foregoing through the court’s ecf system on all registered ecf participants who have appeared in this case and by mail to all of the parties on the attached mailing matrix. /s/ Kevin R. McCarthy Kevin R. McCarthy


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