DKT 411 TEXAS REPUBLIC BANK, N.A.’S SURREPLY TO RECEIVER’S REPLY IN SUPPORT OF ITS 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 FRISCO GATE PROPERTY, (II) AUTHORIZE THE SALE FREE AND CLEAR OF ALL LIENS AND (III) STAY ACCRUAL OF POST RECEIVERSHIP DEFAULT RATE INTEREST

On 11/20/23, Texas Republic Bank, N.A. respectfully requests that the Court approve the sale of the Frisco Gate Property Free and Clear of All Liens, allow Texas Republic Bank, N.A.’s interest to continue to accrue and the Maximum Rate as allowed under the Note until closing, deny payment of any claim of Palisades TC, LLC at closing prior to Texas Republic Bank, N.A. being paid in full, and to the extent the Court seeks to bifurcate the claim of Texas Republic Bank, N.A., that the lien of Texas Republic Bank, N.A. be transferred to the proceeds from the sale of the Frisco Gate Property with the same priority as the original Note and Deed of Trust until such time as said claims are allowed and for such other relief as is just and proper.