Case 6:17-bk-17630-WJ Doc 56 Filed 06/01/18 Entered … lyle cocking, chapter: ... lp purchase price...

This form is mandatory. It has been approved for use in the United States Bankruptcy Court for the Central District of California.

December 2012 F 6004-2.NOTICE.SALE

Sale Date: Time:

Location:

Type of Sale: Public Private Last date to file objections:

Description of property to be sold: ___________________________________________________________________

Terms and conditions of sale: _______________________________________________________________________

Proposed sale price: _________________________________

Attorney or Party Name, Address, Telephone & FAX Nos., State Bar No. & Email Address

FOR COURT USE ONLY

Individual appearing without attorneyAttorney for:

UNITED STATES BANKRUPTCY COURT CENTRAL DISTRICT OF CALIFORNIA - DIVISION

CASE NO.:

CHAPTER:

In re:

NOTICE OF SALE OF ESTATE PROPERTY

Debtor(s).

Lynda T. Bui, Trustee 3550 Vine Street, Suite 210 Riverside CA 92507 Telephone: (949) 340-3400 Facsimile: (949) 340-3000 Email: [email protected] Chapter 7 Trustee

RIVERSIDE DIVISION

STEVEN LYLE COCKING,

6:17-bk-17630-WJ

7

Bids Due by: 6/19/2018 at 5:00 p.m. (California time)Final Bidding Round: at court hearing set forth below

June 26, 2018 1:00 p.m.

Hearing: Courtroom 304, 3420 Twelfth St., Riverside, CA 92501 - see attached for Bidding Procedures

June 12, 2018

The Estate's 3.067% interest in Cocking Partners, LP

Purchase price of $75,000, subject to the Bid Procedures set forth in the attached. The Successful Bidder shall take title to the fractional partnership interest on an “as is - where as” basis without representations or warranties of any kind, expressed or implied, concerning the value, condition or fitness of purpose forany use thereof, in particular - subject to all existing liens and encumbrances. SEE ATTACHED FOR MORE INFORMATION.

$75,000, subject to overbids

Case 6:17-bk-17630-WJ Doc 56 Filed 06/01/18 Entered 06/01/18 13:59:00 Desc Main Document Page 1 of 30


December 2012 F 6004-2.NOTICE.SALE

Overbid procedure (if any): _________________________________________________________________________

If property is to be sold free and clear of liens or other interests, list date, time and location of hearing:

Contact person for potential bidders (include name, address, telephone, fax and/or email address):

Date:

Bids due by 6/19/2018 at 5:00 p.m. (California time). Final bidding round held at the Court hearing on the Sale Motion. Potential bidders must bid an initial amount of at least $5,000 over the Purchase Price;

minimum bid increments thereafter shall be $500. SEE ATTACHED FOR MORE INFORMATION.

Sale is not free and clear of liens.

Court hearing to be held on June 26, 2018 at 1:00 p.m. U.S. Bankruptcy Court

3420 Twelfth Street, Courtroom 304Riverside, CA 92501

Lynda T. Bui, Chapter 7 Trustee

3550 Vine Street, Suite 201Riverside, CA 92507

Telephone: (949) 340-3400Facsimile: (951) 275-9303Fax: (949) 340-3000

Email: [email protected]

06/01/2018

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December 2012 Page 1 F 9013-1.1. NOTICE

1. TO (specify name): _____________________________________________________________________________

2. NOTICE IS HEREBY GIVEN that on the following date and time and in the indicated courtroom, Movant in the above- captioned matter will move this court for an Order granting the relief sought as set forth in the Motion andaccompanying supporting documents served and filed herewith. Said Motion is based upon the grounds set forth inthe attached Motion and accompanying documents.

3. Your rights may be affected. You should read these papers carefully and discuss them with your attorney, if youhave one. (If you do not have an attorney, you may wish to consult one.)

Attorney or Party Name, Address, Telephone & FAX Nos., State Bar No. & Email Address

FOR COURT USE ONLY

Individual appearing without attorneyAttorney for:

UNITED STATES BANKRUPTCY COURT CENTRAL DISTRICT OF CALIFORNIA - DIVISION

CASE NO.:

CHAPTER:

In re:

NOTICE OF MOTION FOR:

(Specify name of Motion)

DATE: TIME: COURTROOM: PLACE:

Debtor(s).

Lynda T. Bui, Chapter 7 Trustee 3550 Vine Street, Suite 210 Riverside, California 92507 Telephone: (949) 340-3400 Facsimile: (949) 340-3000 Email: [email protected]

RIVERSIDE DIVISION

6:17-bk-17630-WJ

STEVEN LYLE COCKING, 7

ORDER: (1) APPROVING THE SALE OF THE ESTATE'S INTEREST IN COCKING PARTNERS, LP PURSUANT TO CODE §363(b)(1), INCLUDING BREAK-UP FEE, SUBJECT TO OVERBIDS, COMBINED WITH NOTICE OF BIDDING PROCEDURES AND REQUEST FOR APPROVAL OF THE BIDDING PROCEDURES UTILIZED; AND (2) GRANTING RELATED RELIEF

06/26/20181:00 pm

304U.S. Bankruptcy Court3420 Twelfth StreetRiverside, CA 92501-3819

Debtor and his counsel, the United States Trustee, all creditors and other parties in interest

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December 2012 Page 2

4. Deadline for Opposition Papers: This Motion is being heard on regular notice pursuant to LBR 9013-1. If you wishto oppose this Motion, you must file a written response with the court and serve a copy of it upon the Movant orMovant’s attorney at the address set forth above no less than fourteen (14) days prior to the above hearing date. Ifyou fail to file a written response to this Motion within such time period, the court may treat such failure as a waiver ofyour right to oppose the Motion and may grant the requested relief.

5. Hearing Date Obtained Pursuant to Judge’s Self-Calendaring Procedure: The undersigned hereby verifies thatthe above hearing date and time were available for this type of Motion according to the judge’s self-calendaringprocedures.

Date:Printed name of law firm

Signature

Printed name of attorney

06/01/2018

/s/ Lynda T. Bui

Lynda T. Bui, Chapter 7 Trustee


Statement of Information in Compliance with LBR 6004-1(c)(3)

LBR 6004-1(c)(3) Requirement

Information

LBR 6004-1(c)(3)(A) Date, Time, and Place of the hearing on the proposed sale:

Hearing Date and Time: June 26, 2018 at 1:00 p.m. Hearing Place: U.S. Bankruptcy Court 3420 Twelfth Street, Courtroom 304

Riverside, CA 92501

LBR 6004-1(c)(3)(B) Name and address of the proposed buyer:

Partnership Liquidity Investors, IV (“Buyer”) 1511 Kings Road Newport Beach, CA 92663

LBR 6004-1(c)(3)(C) Description of the property to be sold:

3.067% interest in Cocking Partners, LP (the “Fractional Partnership Interest”)

LBR 6004-1(c)(3)(D) Terms and conditions of the proposed sale, including the price and all contingencies:

Subject to the Bid Procedures set forth below, the Fractional Partnership Interest will be sold to the Buyer for $75,000, or an amount as increased by successful overbid, pursuant to the terms and conditions set forth in the Agreement for Purchase and Sale of Partnership Interest (“Agreement”) attached as Exhibit “1” to the Declaration of Lynda T. Bui (“Bui Declaration”) annexed to the Sale Motion.

LBR 6004-1(c)(3)(E) Whether the proposed sale is free and clear of liens, claims or interests, or subject to them, and a description of all such liens, claims or interests:

The Buyer or Successful Bidder, as the case may be, shall take title to the Fractional Partnership Interest on an “as is – where is” basis without representations or warranties of any kind, expressed or implied, being given by the Seller, concerning the value, condition or fitness of purpose for any use thereof, in particular – subject to all existing liens and encumbrances against the Fractional Partnership Interest.

LBR 6004-1(c)(3)(F) Whether the proposed sale is subject to higher and better bids:

Yes - See the Bid Procedures set forth in the Sale Motion.

LBR 6004-1(c)(3)(G) Consideration to be received by the Estate, including estimated commissions, fees and other costs of sale:

The Estate is expected to receive at least $75,000 or an amount as increased by a successful overbid.

LBR 6004-1(c)(3)(H) If authorization is sought to pay commission, the identity of the auctioneer, broker, or sales agent and the amount or percentage of the proposed commission to be paid:

There is no broker that will be involved in the sale transaction, and no escrow company will be utilized. It is anticipated that there will be no costs associated with the sale other than regular administrative costs of the Debtor’s Estate.

LBR 6004-1(c)(3)(I) A description of the estimated or possible tax consequences to the Estate, if known, and how any tax liability generated by the sale of the property will be paid:

Although it is anticipated there will not be any capital gains tax consequences, at this time, the Trustee does not know for certain what the capital gains taxes liability will be, if any, generated by the sale. In the event that there is any tax liability generated from the sale of the Prestige Stock that is a liability of the Estate, it is anticipated that such taxes will be minimal and will be paid from the proceeds of the sale.

LBR 6004-1(c)(3)(J) Date which objection must be filed and served:

Objections, if any, must be filed and served 14 days prior to the Hearing Date or June 12, 2018.


SALE MOTION


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Sale Motion TC Cocking re Fractional Partnership Interest.docx23054-000\EXP. 56

1CHAPTER 7 TRUSTEE 3550 Vine Street

Suite 210 Riverside CA 92507

Lynda T. Bui, Trustee 3550 Vine Street, Suite 210 Riverside, California 92507 Telephone: (949) 340-3400 Facsimile: (949) 340-3000 Email: [email protected] Chapter 7 Trustee

UNITED STATES BANKRUPTCY COURT

CENTRAL DISTRICT OF CALIFORNIA, RIVERSIDE DIVISION

In re STEVEN LYLE COCKING, Debtor.

Case No. 6:17-bk-17630-WJ Chapter 7 CHAPTER 7 TRUSTEE’S MOTION FOR ORDER:

(1) APPROVING THE SALE OF THE ESTATE’S INTEREST IN COCKING PARTNERS, LP PURSUANT TO BANKRUPTCY CODE §363(b)(1), INCLUDING BREAK-UP FEE, SUBJECT TO OVERBIDS, COMBINED WITH NOTICE OF BIDDING PROCEDURES AND REQUEST FOR APPROVAL OF THE BIDDING PROCEDURES UTILIZED; AND

(2) GRANTING RELATED RELIEF; MEMORANDUM OF POINTS AND AUTHORITIES AND DECLARATION OF LYNDA T. BUI IN SUPPORT THEREOF Hearing Date: Date: June 26, 2018 Time: 1:00 p.m. Place: Courtroom 304 3420 Twelfth Street

Riverside, California 92501

TO THE HONORABLE WAYNE E. JOHNSON, UNITED STATES BANKRUPTCY

JUDGE, THE OFFICE OF THE UNITED STATES TRUSTEE, THE DEBTOR AND ALL

INTERESTED PARTIES AND THEIR COUNSEL OF RECORD:

///


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I. INTRODUCTION

Lynda T. Bui, the Chapter 7 Trustee (“Trustee”) for the bankruptcy estate

(“Estate”) of Steven Lyle Cocking (“Debtor”), brings this Motion for Order: (1) Approving

the Sale of the Estate’s Interest in Cocking Partners, LP Pursuant to Bankruptcy Code §

363(b)(1), Including Break-Up Fee, Subject to Overbids, Combined With Notice of

Bidding Procedures and Request for Approval of the Bidding Procedures Utilized; and

(2) Granting Related Relief (“Sale Motion”) and respectfully represents as follows.

II. BACKGROUND FACTS

A. Case Commencement

The Debtor filed a voluntary petition under Chapter 7 of the Bankruptcy Code

September 12, 2017. The deadline for filing claims was February 20, 2018 (government

claims were due by March 12, 2018. As of May 25, 2018, the Claim Register reflects a

total of nineteen claims filed in the aggregate amount of $1,231,275.17, of which

$27,317.73 as been asserted as priority and $1,203,957.44 has been asserted as

general unsecured.

B. The Fractional Partnership Interest

In his Schedule A/B, item 19, the Debtor indicated that he has a “non-

transferrable interest” of 3.067% in Cocking Partners, LP (the “Partnership”), his

“parent’s partnership with non-guaranteed & discretionary distributions” (the “Fractional

Partnership Interest”). The Debtor further states that “due to loses [sic] there will be no

regular distributions for the next few years” and values his interest at $10,000. The

Debtor did not claim an exemption in the Fractional Partnership Interest.

The Trustee is not aware of any liens or encumbrances impacting the Debtor’s

interest in the Fractional Partnership Interest. The Trustee’s accountant has reviewed

and analyzed the Partnership Agreement, the Partnership’s tax returns and financial

records for 2014, 2015 and 2016, as well as a broker’s opinion of value for each of the

five properties located in San Diego that are held by the Partnership.

///


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Based on the accountant’s review, the Trustee believes that the value and/or

marketability of the Fractional Partnership Interest is greater than the amount scheduled

by the Debtor.

III. RELIEF REQUESTED BY THE SALE MOTION

Through this Sale Motion, subject to the Bid Procedures set forth below, the

Trustee seeks a Court order to sell the Fractional Partnership Interest to Partnership

Liquidity Investors, IV (“Buyer”) for $75,0001, or an amount as increased by successful

overbid, pursuant to the terms and conditions set forth in the Agreement for Purchase

and Sale of Partnership Interest (“Agreement”) attached as Exhibit “1” to the

Declaration of Lynda T. Bui (“Bui Declaration”). The Buyer or Successful Bidder, as the

case may be, shall take title to the Fractional Partnership Interest on an “as is” basis,

subject to all existing liens and encumbrances and without warranty to the validity, value

or marketability of the Estate’s title to the Fractional Partnership Interest.

IV. NOTICE OF BID PROCEDURES

The Trustee has determined that it would benefit the Estate to permit all

interested parties to receive information and bid for the Fractional Partnership Interest

instead of selling the Fractional Partnership Interest to the Buyer on an exclusive basis.

Accordingly, in order to obtain the highest and best offer for the benefit of the creditors

of this Estate, the Trustee also seeks Court approval of the following bid procedures

(“Bid Procedures”):

a. Potential bidders must bid an initial amount of at least $5,000 over the Purchase Price, or $80,000. Minimum bid increments thereafter shall be $500. The Trustee shall have sole discretion in determining (i) the other procedures to be utilized for bidding, (ii) which overbid is the best for the Estate and will seek approval from the Court of the same.

b. In the event of a successful overbid, whether an initial overbid or a subsequent overbid, Buyer shall be paid a break-up fee of $2,500 (“Break-Up Fee”), which is to reimburse the Buyer for its attorneys’ fees and costs incurred in conducting its due diligence, negotiating the Agreement, appearing at the hearing on the approval of the Agreement, and reviewing the moving papers (and any opposition and reply thereto). ///

1 This is the highest and best offer the Trustee received from interested buyers.


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c. Bids must be in writing and be received by the Trustee on or before

5:00 p.m. (California time) the date that is seven days prior to the Court hearing on the Trustee’s motion for a Court order approving the sale of the Fractional Partnership Interest (“Sale Motion”). Bids must be accompanied by certified funds in an amount equal to three percent of the overbid purchase price.

d. The bidder must also provide evidence of having sufficient specifically committed funds to complete the transaction or a lending commitment for the bid amount and such other documentation relevant to the bidder's ability to qualify as the purchaser of the Fractional Partnership Interest and ability to close the sale and immediately and unconditionally pay the winning bid purchase price at closing.

e. The bidder must seek to acquire the Fractional Partnership Interest on terms and conditions not less favorable to the Estate than the terms and conditions to which the Buyer has agreed to purchase the Fractional Partnership Interest as set forth in the Agreement with the Buyer including no contingencies and closing on the sale in the same time parameters as the Buyer.

f. All competing bids must acknowledge that the Fractional Partnership Interest is being sold on an “AS IS – WHERE IS” basis without representations or warranties of any kind, expressed or implied, being given by the Seller, concerning the value, condition or fitness of purpose for any use thereof, in particular - subject to all existing liens and encumbrances against the Fractional Partnership Interest. Buyer represents and warrants that it is purchasing the Fractional Partnership Interest as a result of its own investigations and is not buying the Estate’s interest in the Fractional Partnership Interest pursuant to any representation made by any broker, agent, accountant, attorney or employee acting at the direction or on behalf of the Seller. Buyer acknowledges that Buyer has investigated the value of the Fractional Partnership Interest and, upon Bankruptcy Court approval of this Agreement, Buyer forever waives, for itself, and its successors and assigns, any and all claims against the Estate and the Seller, both as Trustee and individually, and her attorneys, agents, and employees, arising or which might otherwise arise in the future concerning the Fractional Partnership Interest.

g. If overbids are received, the final bidding round shall be held at the hearing on the Trustee’s Sale Motion seeing approval of the Agreement and the sale of the Fractional Partnership Interest, or if rescheduled, upon telephonic notice to the Buyer and the parties having submitted overbids in order to allow all potential bidders the opportunity to overbid and purchase the Fractional Partnership Interest. At the final bidding round, the Trustee will, in the exercise of her business judgment and subject to Court approval, accept the bidder who has made the highest and best offer to purchase the Fractional Partnership Interest, consistent with the Bid Procedures (“Successful Bidder”). At the hearing on the Sale Motion, the Trustee will seek entry of an order, inter alia, authorizing and approving the sale of the Fractional Partnership Interest to the Successful Bidder. The hearing on the Sale Motion may be adjourned or rescheduled without notice other than by an announcement of the adjourned date at the hearing on the Sale Motion. In the event the Successful Bidder fails to close on the sale within the time parameters approved by the Court, the Trustee shall retain the Successful Bidder's deposit and will be released from her obligation to sell the Fractional Partnership Interest to the Successful Bidder and may then sell the Fractional Partnership Interest to the First Back-Up Bidder approved by the Court. In the event First Back-Up Bidder fails to close on the sale within the time parameters approved by the Court, the Trustee shall retain the First Back-Up Bidder's deposit and will be released from the obligation to sell the Fractional Partnership Interest to the First Back-Up Bidder and may then sell the Fractional Partnership Interest to the Second Back-Up Bidder approved by the Court.


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The Bid Procedures will be set forth in the Notice of the Sale Motion. The Bid

Procedures will be provided to all creditors and any potential bidders or parties who

have shown an interest in the Fractional Partnership Interest. In addition, a Notice of

Sale of Estate Property will be filed with the Court for posting on the Court’s website

under the link “Current Notices of Sales”, thereby giving notice to additional potential

interested parties. Based on the foregoing, the Trustee believes that under the

circumstances of this case, the Fractional Partnership Interest will have been

appropriately marketed for overbidding.

V. ARGUMENT2

A. There is a Good Business Reason for the Sale and the Sale is in the Best

Interest of the Estate.

The duties of a trustee in a Chapter 7 filing are enumerated in 11 U.S.C. §704,

which provides in relevant part as follows:

(a) The trustee shall—

(1) collect and reduce to money the property of the estate for which such trustee serves, and close such estate as expeditiously as is compatible with the best interests of parties in interest; (2) be accountable for all property received;

. . .

Further, the Trustee, after notice and hearing, may sell property of the estate. 11

U.S.C. § 363(b). Courts ordinarily will approve a proposed sale if there is a good

business reason for the sale and the sale is in the bests interests of the estate. In re

Wilde Horse Enterprises, Inc., 136 B.R. 830, 841 (Bankr. C.D. Cal. 1991); In re Lionel

Corp., 722 F.2d 1063, 1069 (2d Cir. 1983).

Here, the facts surrounding the sale support the Trustee’s business decision that

the proposed sale is in the best interests of the Estate and its creditors. Through the

sale, the Trustee anticipates generating funds of $75,000, or an amount as increased by

successful overbid. The Trustee understands that the general partner of the 2 Although Local Bankruptcy Rule 6004-1(c)(2)(C) does not require that a memorandum of points

and authorities be filed in support of the Sale Motion, the Trustee is nevertheless submitting one.


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Partnership may participate in the overbid. If the Sale Motion is not approved, the value

of the Estate’s interest in the Fractional Partnership Interest may be lost. The Trustee

does not know of any benefits that may arise by delaying the sale. In such event, the

Estate will not receive any benefit from the Fractional Partnership Interest. As such,

through this Sale Motion, the Trustee will preserve a benefit for creditors which will be

lost if the Sale Motion is not granted.

B. The Court Has the Authority to Approve the Bidding Procedures

Implementation of the Bid Procedures is an action outside of the ordinary course

of the business. Bankruptcy Code Section 363(b)(1) provides that a trustee “after notice

and hearing, may use, sell or lease, other than in the ordinary course of business,

property of the estate.” 11 U.S.C. § 363(b)(1). Furthermore, under Bankruptcy Code

Section 105(a), “[t]he court may issue any order, process, or judgment that is necessary

or appropriate to carry out the provisions of this title.” 11 U.S.C. § 105(a).

The most important benefit of the Bid Procedures to the Estate is that their

implementation will enable the consummation of the proposed sale. Implementation of

the Bid Procedures is an essential component of consummating the sale of the

Fractional Partnership Interest and maximizing the value of the Fractional Partnership

Interest for the Estate and creditors. The Bid Procedures proposed by the Trustee are

fair and provide for a “level playing field” for all prospective bidders with respect to the

Fractional Partnership Interest.

Thus, pursuant to Bankruptcy Code sections 363(b)(1) and 105(a), this Court

may approve the Bid Procedures, which will assist the Trustee to obtain the best

possible price on the best possible terms for the Fractional Partnership Interest.

C. The Proposed Break-Up Fee Should be Approved

As a part of the proposed Agreement with the Buyer for the purchase of

Fractional Partnership Interest, the Buyer has required that it be paid the $2,500 Break-

Up Fee in the event that an overbid situation occurs and the Buyer is not the Successful

Bidder of the Fractional Partnership Interest.


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1. The Break-Up Fee is Reasonable

As stated by the court in In re Financial News Network, 126 B.R. 152 (D.C.,

S.D.N.Y. 1991) at 154, “A break-up fee is an incentive payment to an unsuccessful

bidder who placed the estate property in a sales configuration mode . . . to attract other

bidders to the auction.” In addition, as stated by the District Court in In re Integrated

Resources, Inc., 147 B.R. 650, at 659-660 (D.C., S.D.N.Y. 1992). Break-up fees are important tools to encourage bidding and to maximize the value of the debtor’s assets. The usual rule is that if break-up fees encourage bidding, they are enforceable; if they stifle bidding they are not enforceable. In fact, because the directors of a corporation have a duty to encourage bidding, break-up fees can be necessary to discharge the director’s duties to maximize value. (citing CRTF Corp. v. Federated Department Stores, Inc., 683 F.Supp. 422, 441 (S.D. N.Y. 1988)).

Moreover, as stated in In re 995 Fifth Avenue Assocs., L.P., 96 B.R. 24, 29

(Bankr. S.D. N.Y. 1989): Outside bankruptcy, the business judgment rule normally applies to the board’s use of a defensive strategy, such as a break-up fee. . . In assessing the incentive effect of the break-up fee, a court should determine whether the dollar amount of the fee is so substantial that it has a chilling affect on other prospective bidders. In making this determination, the court should consider whether the proposed acquiror attracted other bidders or simply received a potential windfall. Break-up fees and other strategies may be legitimately necessary to convince a white knight to enter the bidding by providing some form of compensation for the risks it is undertaking . . . A break-up fee should constitute a fair and reasonable percentage of the proposed purchase price, and should be reasonably related to the risk, effort, and expenses of the prospective purchaser. When reasonable in relation to the bidder's efforts and to the magnitude of the transaction, break-up fees are generally permissible.

In this case, the Trustee readily acknowledges that a significant amount of time,

effort and expense will have been incurred by the Buyer in performing its due diligence

and negotiating the terms of the sale. The Break-Up Fee represents approximately

3.33% of the Purchase Price. It is designed to compensate the Buyer for the risks it is

undertaking in the transaction, including the attorneys’ fees and costs incurred by the


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Buyer in negotiating the purchase of Fractional Partnership Interest, reviewing the

moving papers and any opposition thereto, and appearing at any hearing on this Sale

Motion. More importantly, the Break-Up Fee is only payable in the event that there is a

successful overbid.

The Court should note that the Break-Up Fee is only payable in the event that the

sale closes and the Buyer is not the Successful Bidder, thereby distinguishing these

facts from those presented in In re Hup Industries, Inc., 140 B.R. 191 (Bankr. N.D. Ohio

1992), wherein the court did not approve the break-up fee arrangement when the party

proposed to receive the break-up fee was to receive the same regardless of the

outcome of the proposed sale in the event overbidding took place. Thus, the Trustee

requests the Court approve the Break-Up Fee proposed to be paid to the Buyer in the

event the sale closes and the Buyer is not the purchaser.

D. The Court has the Authority to Waive the Fourteen-Day Stay of Sale

Federal Rule of Bankruptcy Procedure 6004(h) provides that “[a]n order

authorizing the use, sale or lease of property other than cash collateral is stayed until

the expiration of 14 days after entry of the order, unless the Court orders otherwise.”

Fed. Rule Bankr. P. 6004(h). The Trustee desires to close the sale of the Fractional

Partnership Interest as soon as practicable after entry of an order approving the sale.

Accordingly, the Trustee requests that the Court, in the discretion provided it under

Federal Rule of Bankruptcy Procedure 6004(h), waive the fourteen-day stay

requirement.

VI. CONCLUSION

WHEREFORE, based upon the foregoing, the Trustee respectfully submits that

good cause exists for granting the Sale Motion and requests that the Court enter an

order as follows:

1. Approving the Bid Procedures.

2. Approving the proposed Break-Up Fee.

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3. Authorizing the Trustee to sell the Fractional Partnership Interest on an

as-is, where-as basis, without any warranties or representations, to the Buyer (or

Successful Bidder) for $75,000, or an amount as increased by successful overbid,

pursuant to the terms and conditions as set forth in the Agreement for Purchase and

Sale of Partnership Interest attached as Exhibit “1” to the Bui Declaration annexed

hereto.

4. Authorizing the Trustee to sign any and all documents convenient and

necessary in pursuit of the sale of the Fractional Partnership Interest pursuant to the

terms of the Agreement governing the sale, including but not limited to any and all

conveyances contemplated by the sale.

5. Finding that the Purchase Price constitutes fair market value for the

Fractional Partnership Interest.

6. Finding that notice of the transactions contemplated hereby and of the

terms of the Agreement was good and sufficient and was provided timely to all creditors

and parties in interest, including, without limitation, any and all creditors holding liens or

encumbrances on the Fractional Partnership Interest.

7. Making a determination that the Buyer is in good faith pursuant to

Bankruptcy Code Section 363(m).

8. Waiving the fourteen day stay of the order approving the sale under

Federal Rules of Bankruptcy Procedure 6004(h) such that the sale can close as soon as

possible after entry of the Court order approving the Sale Motion.

9. For such other and further relief as the Court deems just and proper under

the circumstances of this case. Dated: June 1, 2018 /s/ Lynda T. Bui

______________________________________ Lynda T. Bui Solely in her capacity as the Chapter 7 trustee for the bankruptcy estate of Steven Lyle Cocking


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DECLARATION OF LYNDA T. BUI

I, Lynda T. Bui, declare:

1. I am the duly appointed, qualified and acting Chapter 7 Trustee for the

bankruptcy estate of In re Steven Lyle Cocking, Case No. 6:17-bk-17630-WJ (“Debtor”).

I have personal knowledge of the facts set forth herein, and if called and sworn as a

witness, I could and would competently testify thereto, except where matters are stated

on information and belief, in which case I am informed and believe that the facts so

stated are true and correct.

2. I make this Declaration in support of my Motion for Order: (1) Approving the

Sale of the Estate’s Interest in Cocking Partners, LP Pursuant to Bankruptcy Code §

363(b)(1), Subject to Overbids, Combined With Notice of Bidding Procedures and

Request for Approval of the Bidding Procedures Utilized; and (2) Granting Related Relief

(“Sale Motion”). Unless otherwise noted, capitalized terms herein have the meaning as

set forth in the Sale Motion.

3. In his Schedule A/B, item 19, the Debtor indicated that he has a “non-

transferrable interest” of 3.067% in Cocking Partners, LP (the “Partnership”), his

“parent’s partnership with non-guaranteed & discretionary distributions” (the “Fractional

Partnership Interest”). The Debtor further states that “due to loses [sic] there will be no

regular distributions for the next few years” and values his interest at $10,000. The

Debtor did not claim an exemption in the Fractional Partnership Interest.

4. I am not aware of any liens or encumbrances impacting the Debtor’s

interest in the Fractional Partnership Interest. My accountant has reviewed and analyzed

the Partnership Agreement, the Partnership’s tax returns and financial records for 2014,

2015 and 2016, as well as a broker’s opinion of value for each of the five properties

located in San Diego that are held by the Partnership.

5. Based on my accountant’s review, I believe that the value and/or

marketability of the Fractional Partnership Interest is greater than the amount scheduled

by the Debtor. In addition, I solicited offers from various parties. The $75,000 offer from


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the Buyer is the highest and best offer received. In fact, the offer I received from the

general partner of the Partnership is less than half of the $75,000 offer.

6. Through the Sale Motion, subject to the Bid Procedures, I seek a Court

order to sell the Fractional Partnership Interest to the Buyer for $75,000, or an amount as

increased by successful overbid, pursuant to the terms and conditions set forth in the

Agreement for Purchase and Sale of Partnership Interest (“Agreement”) attached hereto

as Exhibit “1”.

7. The Buyer or Successful Bidder, as the case may be, shall take title to the

Fractional Partnership Interest on an “as is” basis, subject to all existing liens and

encumbrances and without warranty to the validity, value or marketability of the Estate’s

title to the Fractional Partnership Interest.

8. I have no relationship with the Buyer other than as the trustee for the

Debtor’s Estate and as buyer/seller for the transaction for the sale of the Fractional

Partnership Interest. There was no self-dealing associated with this sale.

9. The Estate does not have the funds to obtain a formal written appraisal of

the value of the Fractional Partnership Interest. Based on the Debtor’s Schedules and

information regarding the Partnership and my proposed accountant’s review of the

Partnership’s books and records, I believe (i) that the value of the Fractional Partnership

Interest is greater than the amount scheduled by the Debtor; and (ii) the employment of a

broker to market the Fractional Partnership Interest for sale is not warranted.

Accordingly, there is no broker that will be involved in the sale transaction, and no

escrow company will be utilized. It is anticipated that there will be no costs associated

with the sale other than regular administrative costs of the Debtor’s Estate.

10. I have determined that it would benefit the Estate to permit all interested

parties to receive information and bid for the Fractional Partnership Interest instead of

selling the Fractional Partnership Interest to the Buyer on an exclusive basis.

Accordingly, in order to obtain the highest and best offer for the benefit of the creditors of

this Estate, I also seek Court approval of the bid procedures (“Bid Procedures”) and the


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Break-Up Fee described in the Sale Motion. The Bid Procedures will be set forth in the

Notice of the Sale Motion. The Bid Procedures will be provided to all creditors and any

potential bidders or parties who have shown an interest in the Fractional Partnership

Interest. In addition, a Notice of Sale of Estate Property will be filed with the Court for

posting on the Court’s website under the link “Current Notices of Sales”, thereby giving

notice to additional potential interested parties. Based on the foregoing, the I believe

that under the circumstances of this case, the Fractional Partnership Interest will have

been appropriately marketed for overbidding.

11. I believe that the proposed sale, subject to overbids, will be at fair market

value. Given that the sale is subject to overbids, it is anticipated that the Estate will

receive the best and highest value for the Fractional Partnership Interest and therefore

the proposed sale price is fair and reasonable.

12. Although it is anticipated there will not be any capital gains tax

consequences because I am selling only the interest in the Partnership, at this time, I do

not know for certain what the capital gains taxes liability will be, if any, generated by the

sale. In the event that there is any tax liability generated from the sale of the Fractional

Partnership Interest that is a liability of the Estate, it is anticipated that such taxes will be

minimal and will be paid from the proceeds of the sale.

13. For the reasons set forth in the Sale Motion and this Declaration, I

respectfully request that the Court grant the Sale Motion so that I do not lose this

favorable business opportunity to net a substantial amount of money for the Estate.

I declare under penalty of perjury under the laws of the United States of America

that the foregoing is true and correct.

Executed on June 1, 2018, at Riverside, California.

/s/ Lynda T. Bui Lynda T. Bui


EXHIBIT “1”

Agreement for Purchase and Sale of Partnership Interest

Page 13


EXHIBIT "1" Page 14


EXHIBIT "1" Page 15


EXHIBIT "1" Page 16


EXHIBIT "1" Page 17


This form is mandatory. It has been approved for use by the United States Bankruptcy Court for the Central District of California.

June 2012 F 9013-3.1.PROOF.SERVICE

PROOF OF SERVICE OF DOCUMENT I am over the age of 18 and not a party to this bankruptcy case or adversary proceeding. My business address is: 100 Spectrum Center Drive, Suite 600, Irvine, California 92618 A true and correct copy of the foregoing document entitled (specify): NOTICE OF SALE OF ESTATE PROPERTY will be served or was served (a) on the judge in chambers in the form and manner required by LBR 5005-2(d); and (b) in the manner stated below: 1. TO BE SERVED BY THE COURT VIA NOTICE OF ELECTRONIC FILING (NEF): Pursuant to controlling General Orders and LBR, the foregoing document will be served by the court via NEF and hyperlink to the document. On (date) June 1, 2018, I checked the CM/ECF docket for this bankruptcy case or adversary proceeding and determined that the following persons are on the Electronic Mail Notice List to receive NEF transmission at the email addresses stated below:

Volvo Financial Services, a division of VFS US LLC: Megan M Adeyemo [email protected], [email protected]

Chapter 7 Trustee: Lynda T. Bui (TR) [email protected], [email protected] Volvo Financial Services, a division of VFS US LLC: Jeffrey D Cawdrey [email protected],

[email protected]; [email protected] Attorney for Ditech Financial LLC: Julian T Cotton [email protected] Volvo Financial Services, a division of VFS US LLC: Jennifer Eileen Duty [email protected],

[email protected] Notice for California Coast Credit Union: Cindy D Fields [email protected] Interested Party: Raffi Khatchadourian [email protected] Attorney for Debtor: Christopher J Langley [email protected], [email protected];

[email protected] Hitachi Capital America Corp.: Richard A Solomon [email protected] Interested Party: United States Trustee (RS) [email protected] Notice for Hyundai Motor Finance Company: Angela C Williams [email protected],

[email protected] Service information continued on attached page 2. SERVED BY UNITED STATES MAIL: On (date) June 1, 2018, I served the following persons and/or entities at the last known addresses in this bankruptcy case or adversary proceeding by placing a true and correct copy thereof in a sealed envelope in the United States mail, first class, postage prepaid, and addressed as follows. Listing the judge here constitutes a declaration that mailing to the judge will be completed no later than 24 hours after the document is filed. Service information continued on attached page 3. SERVED BY PERSONAL DELIVERY, OVERNIGHT MAIL, FACSIMILE TRANSMISSION OR EMAIL (state method for each person or entity served): Pursuant to F.R.Civ.P. 5 and/or controlling LBR, on (date) June 1, 2018, I served the following persons and/or entities by personal delivery, overnight mail service, or (for those who consented in writing to such service method), by facsimile transmission and/or email as follows. Listing the judge here constitutes a declaration that personal delivery on, or overnight mail to, the judge will be completed no later than 24 hours after the document is filed. Service information continued on attached page I declare under penalty of perjury under the laws of the United States that the foregoing is true and correct.

June 1, 2018 Erlanna Lohayza /s/ Erlanna Lohayza Date Printed Name Signature




EMAIL SERVICE LIST Buyer: Partnership Liquidity Investors IV, LLC Attn: Jerome A. Fink/Eugene Davidzon Email: [email protected] Potential Bidders: A. Yoni Miller; QuickLiquidity; Email: [email protected] David Pullman; The Pullman Group, LLC; Email: [email protected]

U.S. MAIL SERVICE LIST

Judge’s Copy: U.S. Bankruptcy Court Attn: Honorable Wayne E. Johnson 3420 Twelfth Street, Suite 385 Riverside, CA 92501 Notice for Partnership Linda L. Cocking General Partner Cocking Partners 4890 Renovo Way San Diego, CA 92124 Debtor, Creditors and Parties in Interest:

DEBTOR STEVEN LYLE COCKING 30143 DESTINY DR MURRIETA, CA 92563-6868

ACCOUNTANT FOR TRUSTEEDONALD T FIFE HAHN FIFE & COMPANY LLP 790 E COLORADO BLVD 9TH FL PASADENA, CA 91101-2193

CREDITOR LISTINGCALIFORNIA COAST CREDIT UNION POB 502080 SAN DIEGO, CA 92150-2080

CREDITOR LISTING DITECH FINANCIAL LLC 14841 DALLAS PARKWAY, SUITE 300 DALLAS, TX 75254-7883

CREDITOR LISTINGEMPLOYMENT DEVELOPMENT DEPT. BANKRUPTCY GROUP MIC 92E P.O. BOX 826880 SACRAMENTO, CA 94280-0001

CREDITOR LISTINGFRANCHISE TAX BOARD BANKRUPTCY SECTION MS: A-340 P.O. BOX 2952 SACRAMENTO, CA 95812-2952

CREDITOR LISTING HAHN FIFE & COMPANY 790 E COLORADO BLVD 9TH FL PASADENA, CA 91101-2193

CREDITOR LISTINGHITACHI CAPITAL AMERICA CORP. C/O RICHARD A. SOLOMON, ESQ. SOLOMON, GRINDLE, LIDSTAD & WINTRINGER 11682 EL CAMINO REAL, SUITE 250 SAN DIEGO, CA 92130-7705

CREDITOR LISTINGHYUNDAI MOTOR FINANCE COMPANY PO BOX 20809 FOUNTAIN VALLEY, CA 92728-0809




CREDITOR LISTING VOLVO FINANCIAL SERVICES, A DIVISION OF VFS PO BOX 26131 7025 ALBERT PICK ROAD, SUITE 105 (27409) GREENSBORO, NC 27409-9539

CREDITOR LISTING4CHANGE ENERGY PO BOX 660361 DALLAS, TX 75266-0361

CREDITOR LISTINGADP 7000 VILLAGE DR, BUENA PARK, CA 90621-2287

CREDITOR LISTING AT ADVANTAGE, INC. 1244 N MAIN STE #203 TOOELE, UT 84074-9839

CREDITOR LISTINGAT&T 208 S. AKARD ST. DALLAS, TX 75202-4206

CREDITOR LISTINGABDIEL SOLIS 70 TIMBERSPIRE LANE SPRING, TX 77380-2843

CREDITOR LISTING ADLINE ISD PO BOX 203989 HOUSTON, TX 77216-3989

CREDITOR LISTINGAGEE BUSINESS SOLUTIONS 75 W. NUEVO RD. STE. E PMB 343 PERRIS, CA 92571-0801

CREDITOR LISTINGAIR RESOURCES BOARD 9480 TELSTAR STE 4 EL MONTE, CA 91731-2988

CREDITOR LISTING AMERICAN EXPRESS P.O. BOX 0001 LOS ANGELES, CA 90096-0001

CREDITOR LISTINGAMERICAN EXPRESS BANK, FSB C/O BECKET AND LEE LLP PO BOX 3001 MALVERN PA 19355-0701

CREDITOR LISTINGAMERICAN EXPRESS CENTURION BANK C/O BECKET AND LEE LLP PO BOX 3001 MALVERN PA 19355-0701

CREDITOR LISTING AMERICAN TRUCKING ASSOCIATIONS 950 N. GLEBE RD. STE 210 ARLINGTON, VA 22203-4181

CREDITOR LISTINGAMEX CORRESPONDENCE PO BOX 981540 EL PASO, TX 79998-1540

CREDITOR LISTINGARGONAUT INSURANCE PO BOX 469011 SAN ANTONIO, TX 78246-9011

CREDITOR LISTING ARVIND TUFFLEY 22523 SPENCE PARK CT SPRING, TX 77373-6581

CREDITOR LISTINGASCENTIUM CAPITAL LLC 23970 HIGHWAY 59 NORTH KINGWOOD, TX 77339-1535

CREDITOR LISTINGBH MANAGEMENT SERVICES 19800 KENSWICK DRIVE HUMBLE, TX 77338-2150

CREDITOR LISTING BMO HARRIS BANK NA 3925 FOUNTAINS DR NE STE 105 CEDAR RAPIDS IA 52411-6620

CREDITOR LISTINGBMO HARRIS BANK, NA P.O. BOX 365 ARLINGTON HEIGHTS, IL 60006-0365

CREDITOR LISTINGBANC OF CALIFORNIA 3 MACARTHUR PLACE STE 100 SANTA ANA, CA 92707-6068

CREDITOR LISTING BILATERAL CREDIT CORP, LLC 1980 PAWTUCKET AVE. STE 2A EAST PROVIDENCE, RI 02914-1715

CREDITOR LISTINGBLUE BEACON PO BOX 856 SALINA, KS 67402-0856

CREDITOR LISTINGBLUE BEACON INTERNATIONAL INC DBA BLUE BEACON TRUCK WASH PO BOX 856 SALINA, KS 67402-0856

CREDITOR LISTING CA BOARD OF EQUALIZATION PO BOX 942879 SACRAMENTO, CA 94279-7072

CREDITOR LISTINGCDTA 1011 CAMINO DEL RIO S., STE. 200 SAN DIEGO, CA 92108-3572

CREDITOR LISTINGCLC LODGING 8111 EAST 32ND STREET NORTH STE 300 WICHITA, KS 67226-2619

CREDITOR LISTING CALIFORNIA CHOICE BENEFIT ADMIN. 721 S. PARKER, SUITE 200 ORANGE, CA 92868-4772

CREDITOR LISTINGCANAVERAL PORT AUTHORITY 445 CHALLENGER RD # 301 CAPE CANAVERAL, FL 32920-4100

PREFERRED ADDRESSCAPITAL ONE PO BOX 30285 SALT LAKE CITY UT 84130-0285




CREDITOR LISTING CARMAX CARE OF CASS INFORMATION SYSTEMS PO BOX 17600 SAINT LOUIS, MO 63178-7600

CREDITOR LISTINGCHERIE JIMENEZ 32255 VIA CESARIO TEMECULA, CA 92592-3832

CREDITOR LISTINGCHRIS REED 2000 HWY 507 SIMSBORO, LA 71275-3574

CREDITOR LISTING CINTAS CORPORATION PO BOX 547, DALLAS, TX 75265

CREDITOR LISTINGCOCKING PARTNERS, LP 4890 RENOVO WAY SAN DIEGO, CA 92124-2455

CREDITOR LISTINGCOLONIAL LIFE PO BOX COLUMBIA, SC 29202

CREDITOR LISTING COMDATA 5301 MARYLAND WAY BRENTWOOD, TN 37027-5028

CREDITOR LISTINGCOMPASS BANK NAJJAR DENABURG APC 2125 MORRIS AVENUE BIRMINGHAM, AL 35203-4274

CREDITOR LISTINGDH GRAPHICS 26377 JEFFERSON AVE. STE A MURRIETA, CA 92562-6976

CREDITOR LISTING DTS 1461 WAFER ROAD HAUGHTON, LA 71037-5801

CREDITOR LISTINGDALLAS LOPEZ CRUM & FORSTER PO BOX 2807 HOUSTON, TX 77252-2807

CREDITOR LISTINGDAVID SAWYER 4609 STEERE DR. SHREVEPORT, LA 71105-3227

CREDITOR LISTING DE LAGE LANDEN FINANCIAL SER. INC. PO BOX 41602 PHILADELPHIA, PA 19101-1602

CREDITOR LISTINGDEPARTMENT OF MOTOR VEHICLES PO BOX 825339 SACRAMENTO, CA 94232-5339

CREDITOR LISTINGDITECH ATTN: BANKRUPTCY PO BOX 6172 RAPID CITY, SD 57709-6172

CREDITOR LISTING EZ TAG 11411 N. SAM HOUSTON PKWY E. HUMBLE, TX 77396-5903

CREDITOR LISTINGELEMENT FINANCIAL 940 RIDGEBROOK RD. SPARKS GLENCOE, MD 21152-9390

CREDITOR LISTINGERICK WITHAM 101 SAUNDERS DR. VALLEJO, CA 94591-6743

CREDITOR LISTING FIRST INSURANCE FUNDING 450 SKOKIE BLVD STE 1000 NORTHBROOK, IL 60062-7917

CREDITOR LISTINGFLATIRON CAPITAL 1700 LINCOLN ST., 12TH FLOOR DENVER, CO 80203-4501

CREDITOR LISTINGFLORIDA HIGH SPEED INTERNET 1311 BEDFORD DRIVE MELBOURNE, FL 32940-1975

CREDITOR LISTING FLORIDA HIGHWAY PATROL PENALTY COLLECTIONS UNIT-MS24 2900 APALACHEE PARKWAY TALLAHASSEE, FL 32399-0500

CREDITOR LISTINGFORD MOTOR CO. PO BOX 309 DEARBORN, MI 48121-0309

CREDITOR LISTINGFRANCHISE TAX BOARD PIT BANKRUPTCY MS: A-340 PO BOX 2952 SACRAMENTO, CA 95812-2952

CREDITOR LISTING FRONTIER COMMUNICATIONS PO BOX 740407 CINCINNATI, OH 45274-0407

CREDITOR LISTINGGCR TIRE CENTERS TRANSWORLD SYSTEMS INC. 500 VIRGINIA DR, SUITE 514 FORT WASHINGTON, PA 19034-2707

CREDITOR LISTINGGEORGE GOST, ESQ. HEMAR, ROUSSO & HEALD LLC 15910 VENTURA BLVD. 12TH FL. ENCINO, CA 91436-2829

CREDITOR LISTING GEORGIA DEPARTMENT OF LABOR 148 ANDREW YOUNG INTERNATIONAL BLVD NE STE 752 ATLANTA, GA 30303-1751

CREDITOR LISTINGGOODMAN PROPERTIES, LLC 17032 PALMDALE ST., UNIT C HUNTINGTON BEACH, CA 92647-8450

CREDITOR LISTINGHALL TRUCK CENTER PO BOX 4905 TYLER, TX 75712-4905




CREDITOR LISTING HARBOR AUTO TRANSPORT 3611 FARQUHAR AVE. LOS ALAMITOS, CA 90720-2004

CREDITOR LISTINGHARRIS COUNTY APPRAISAL DISTRICT 13013 NORTHWEST FWY HOUSTON, TX 77040-6305

CREDITOR LISTINGHARRIS COUNTY TRA C/O JOHN P. DILLMAN LINEBARGER GOGGAN BLAIR & SAMPSON LLP P.O. BOX 3064 HOUSTON, TX 77253-3064

CREDITOR LISTING HARRIS COUNTY TOLL ROAD AUTHORITY HCTRA-VIOLATIONS DEPT 1 PO BOX 4440 HOUSTON, TX 77210-4440

CREDITOR LISTINGHITACHI AUTOMATIVE SYSTEMS INC. 6200 GATEWAY DR. CYPRESS, CA 90630-4842

CREDITOR LISTINGHITACHI CAPITAL AMERICA CORP C/O RICHARD A S SOLOMON, GRINDLE, LIDSTAD & WINTRINGER 11682 EL CAMINO REAL, STE 250 SAN DIEGO, CA 92130-7705

CREDITOR LISTING HYUNDAI FINC ATTN: BANKRUPTCY PO BOX 20809 FOUNTAIN CITY, CA 92728-0809

CREDITOR LISTINGINTERNAL REVENUE SERVICE PO BOX 7346 PHILADELPHIA, PA 19101-7346

CREDITOR LISTINGINTERSTATE CAPITAL CORP. C/O CLANCE CREAL, JR. 1255 COUNTRY CLUB RD. SANTA TERESA, NM 88008-9707

CREDITOR LISTING INTERSTATE CAPITAL CORP. C/O EUGENE SMITH SPEARMAN 1255 COUNTRY CLUB RD. SANTA TERESA, NM 88008-9707

CREDITOR LISTINGINTERSTATE INDUSTRIES INC. 961 GRIMMETT SHREVEPORT, LA 71107-6713

CREDITOR LISTINGJ.J. KELLER PO BOX 6609 CAROL STREAM, IL 60197-6609

CREDITOR LISTING JACK KEY AUTO TRANSPORT 9779 CF HAWN FREEWAY DALLAS, TX 75217-7701

CREDITOR LISTINGJAMES KING 334 COLONY BEND DR. SHREVEPORT, LA 71115-6115

CREDITOR LISTINGJEFF HICKS 620 PINE ACRES DRIVE SHREVEPORT, LA 71107-2219

CREDITOR LISTING JEFFREY SCOTT DISKIN 21806 YUCCA TIP LANE HOUSTON, TX 77073-1629

CREDITOR LISTINGJOHN A. LANGDON 1434 E WALNUT AVE EL SEGUNDO CA 90245-2624

CREDITOR LISTINGJOHN JAJEH PARKING 8610 WYNDHAM VILLAGE DRIVE HOUSTON, TX 77040-1142

CREDITOR LISTING JOHN LANGDON 1434 E WALNUT AVE EL SEGUNDO, CA 90245-2624

CREDITOR LISTINGJOSHUA DISKIN 21806 YUCCA TIP LANE HOUSTON, TX 77073-1629

CREDITOR LISTINGJUSTIN MARTIN 6681 LUCRETIA AVE. MIRA LOMA, CA 91752-2723

CREDITOR LISTING KEN PATRICK 15175 OAKWOOD LANE CHINO HILLS, CA 91709-2630

CREDITOR LISTINGKRISTI PATLAN 44655 LA PAZ RD. TEMECULA, CA 92592-2549

CREDITOR LISTINGLABOR COMMISSIONER, STATE OF CA 464 WEST 4TH STREET, ROOM 348 SAN BERNARDINO, CA 92401-1414

CREDITOR LISTING LINE BARGER GOGGAN BLAIR & SAMPSON 4828 LOOP CENTRAL DRIVE, SUITE 500 HOUSTON, TX 77081-2212

CREDITOR LISTINGLOUISIANA DEPARTMENT OF REVENUE PO BOX 201 BATON ROUGE, LA 70821-0201

CREDITOR LISTINGMARK SKVARCA 817 LAGUNA DRIVE CORONA, CA 92879-1027

CREDITOR LISTING METROGISTICS 110 ROCK CLIFF CT SAINT LOUIS, MO 63123-1154

CREDITOR LISTINGMICHAEL DAVIS 8503 LAKELAND BLVD FORT PIERCE, FL 34951-1380

CREDITOR LISTINGMICHAEL FOLSOM 1308 OAKCREST DR. BRANDON, FL 33510-2361




CREDITOR LISTING MILES MESSENGER 27515 LOCK HAVEN CT. TEMECULA, CA 92591-4466

CREDITOR LISTINGMULTI SERVICE FUEL CARD 8650 COLLEGE BLVD. OVERLAND PARK, KS 66210-1886

CREDITOR LISTINGNTSG - OUR SERVICE DEPARTMENT 1622 N BLACK CANYON HIGHWAY PHOENIX, AZ 85009-2917

CREDITOR LISTING NETWORKFLEET 9868 SCRANTON ROAD SAN DIEGO, CA 92121-1791

CREDITOR LISTINGNEW MEXICO TAX AND REVENUE DEPT POBOX 1928 ALBUQUERQUE, NM 87103-1928

CREDITOR LISTINGPMT SOLUTIONS 2330 130TH AVE NE SUITE C 101 BELLEVUE, WA 98005-1756

CREDITOR LISTING PAUL HERZIG 51 EAST COURT #03 MELBOURNE, FL 32904-4064

CREDITOR LISTINGPETERBILT OF SHREVEPORT 5520 INDUSTRIAL DRIVE EXT BOSSIER CITY, LA 71112-2619

CREDITOR LISTINGPREPASS 510 PARKLAND DR. SANDY, UT 84070-6419

CREDITOR LISTING PUTER WERKZ 10430 PIONEER BLVD, SANTA FE SPRINGS, CA 90670-8243

CREDITOR LISTINGRSI INSURANCE BROKERS 4000 WESTERLY PLACE #110 NEWPORT BEACH, CA 92660-2347

CREDITOR LISTINGRST SERVICE AND REPAIR 1051 HIBISCUS ST COCOA, FL 32927-8737

CREDITOR LISTING RANDAL SHELTON 1267 MARQUISE CT. ROCKLEDGE, FL 32955-4404

CREDITOR LISTINGRON CRAFT 20407 SPOONWOOD DRIVE HUMBLE, TX 77346-1799

CREDITOR LISTINGRONALD MATTHEWS 397 GIFFORD HILL RD. MINDEN, LA 71055-6835

CREDITOR LISTING RONALD RAGUSA 602 AVENIDA CURTA #109 CLERMONT, FL 34714-7091

CREDITOR LISTINGSAM TEUTSCH 1104 SAN SABA ST. BOSSIER CITY, LA 71112

CREDITOR LISTINGSANTANDER BANK N.A. 3 HUNTINGTON QUADRANGLE STE 101N MELVILLE NY 11747-4623

CREDITOR LISTING SANTANDER USA ATTN: BANKRUPTCY DEPARTMENT PO BOX 560284 DALLAS, TX 75356-0284

CREDITOR LISTINGSOUTHERN CALIFORNIA EDISION PO BOX 800 ROSEMEAD, CA 91770-0800

CREDITOR LISTINGSOUTHERN TIRE MART DEPT 143 PO BOX 1000 MEMPHIS, TN 38148-0143

CREDITOR LISTING SPARKLETTS 200 EAGLES LANDING BLVD. LAKELAND, FL 33810-3058

CREDITOR LISTINGSTACEY NICKERSON 6026 FM 2625 E MARSHALL, TX 75672-3829

CREDITOR LISTINGSTEVEN LAWRASON 2016 ALLISON AVE. SHREVEPORT, LA 71120

CREDITOR LISTING STONELEIGH ON KENSWICK 19800 KENSWICK DR. HUMBLE, TX 77338-2150

CREDITOR LISTINGSUNPASS PO BOX 880029 BOCA RATON, FL 33488-0029

CREDITOR LISTINGTEXAS MUTUAL INSURANCE COMPANY 6210 US-290 AUSTIN, TX 78723

CREDITOR LISTING TEXAS TAG PO BOX 650749 DALLAS, TX 75265-0749

CREDITOR LISTINGTEXAS WORKFORCE COMMISSION LABOR MARKET AND CAREER INFORMATION 101 E. 15TH ST., ROOM 0252.1 AUSTIN, TX 78778-0010

CREDITOR LISTINGTONY OQUINDO 3403 MOCKINGBIRD PHARR, TX 78577-7927




CREDITOR LISTING TRANSGUARD GENERAL AGENCY, INC. 7557 RAMBLER RD. DALLAS, TX 75231-4142

CREDITOR LISTINGUNION PACIFIC RAILROAD CO. 1400 DOUGLAS ST. OMAHA, NE 68179-0002

CREDITOR LISTINGUNITED ROAD 10701 MIDDLEBELT ROAD ROMULUS, MI 48174-2714

CREDITOR LISTING UNITED STATES TREASURY 1500 PENNSYLVANIA AVE., NW WASHINGTON, DC 20220-0001

CREDITOR LISTINGVERIZON PO BOX 920041 DALLAS, TX 75392-0041

CREDITOR LISTINGVOLVO FINANCIAL PO BOX 91300 MOBILE, AL 36691-1300

CREDITOR LISTING VOLVO FINANCIAL SERVICES P.O. BOX 26131, GREENSBORO, NC 27402 (336)931-4105, BANKRUPTCYGROUP@VFSC

CREDITOR LISTINGWELLS FARGO PO BOX 29704 PHOENIX, AZ 85038-9704

CREDITOR LISTINGWELLS FARGO BANK, N.A. SMALL BUSINESS LENDING DIVISION P.O. BOX 29482 PHOENIX, AZ 85038-9482

CREDITOR LISTING XFINITY / COMCAST ONE COMCAST CENTER PHILADELPHIA, PA 19103-2833

RETURNED MAIL

UNDELIVERABLE COURTESY NEF

N/A RIVERSIDE DIVISION 3420 TWELFTH STREET, RIVERSIDE, CA 92501-3819

N/A LYNDA T. BUI (TR) SHULMAN HODGES & BASTIAN LLP 3550 VINE STREET, SUITE 210 RIVERSIDE, CA 92507-4175

DUPLICATE COMDATA INC 5301 MARYLAND WAY BRENTWOOD TN 37027-5028

DUPLICATEFRANCHISE TAX BOARD BANKRUPTCY SECTION MS A340 PO BOX 2952 SACRAMENTO CA 95812-2952

DUPLICATE CALIFORNIA COAST CU ATTN: BANKRUPTCY PO BOX 502080 SAN DIEGO, CA 92150-2080

UNDELIVERABLE P. O. BOX 26131, GREENSBORO, NC 27402


Case 6:17-bk-17630-WJ Doc 56 Filed 06/01/18 Entered … lyle cocking, chapter: ... lp purchase price...

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Transcript of Case 6:17-bk-17630-WJ Doc 56 Filed 06/01/18 Entered … lyle cocking, chapter: ... lp purchase price...