DKT 378 RECEIVER’S VERIFIED AND EXPEDITED MOTION TO (I) RATIFY ORDERS APPOINTING APPRAISERS, APPROVING APPRAISALS AND APPROVING SALE OF REAL ESTATE AS REQUIRED BY 28 U.S.C. § 2001 WITH RESPECT TO THE AMERIGOLD SUITES, (II) AUTHORIZE THE SALE FREE AND CLEAR OF ALL LIENS, AND (III) STAY ACCRUAL OF POST-RECEIVERSHIP DEFAULT RATE INTEREST

On 11/01/23, Cort Thomas, as the court appointed Receiver, respectfully submits this Motion for Ratification and Approval of the Amerigold Suites Orders (defined below), by which the Court appointed appraisers, approved appraisals and, following notice and hearing, approved the sale of the Amerigold Suites in reliance on the Initial Receivership Order (defined below). Dkt. Nos. 197, 202. The Receiver also requests that the Court authorize the sale “free and clear” of all liens and equitably stay accrual of all interest at any “default rate” which otherwise accrued from the date of the Initial Receivership Order.