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`DOUGLAS P. WILSON, RECEIVER
`DOUGLAS WILSON COMPANIES
`1620 Fifth Avenue, Suite 400
`San Diego, California 92101
`Telephone:
`(619) 641-1141
`Facsimile:
`(619) 641-1150
`Email:
`dwilson@douglaswilson.com
`
`ELECTRONICALLY
`F I L E D
`
`Superior Court of California,
`County of San Francisco
`04/08/2025
`Clerk of the Court
`BY: RONNIE OTERO
`Deputy Clerk
`
`SUPERIOR COURT OF THE STATE OF CALIFORNIA
`
`FOR THE COUNTY OF SAN FRANCISCO
`
`WELLS FARGO BANK, NATIONAL
`ASSOCIATION, SOLELY IN ITS
`CAPACITY AS TRUSTEE IN TRUST FOR
`HOLDERS OF MRCD 2019-PARK
`MORTGAGE TRUST, COMMERCIAL
`MORTGAGE PASS-THROUGH
`CERTIFICATES, SERIES 2019-PARK
`Plaintiff,
`
`vs.
`
`PARKMERCED OWNER LLC; and DOES
`1-50, inclusive,
`
`Defendants.
`
`Case No. CGC-25-622263
`
`[Assigned for all purposes to Hon. Rochelle C.
`East Department 206]
`
`CORRECTED RECEIVER’S INITIAL
`INVENTORY AND FIRST MONTHLY
`REPORT
`
`-1-
`
`Note: this Receiver’s Initial Inventory and First Monthly Report is being re-filed because the version filed on April 7,
`2025 was inadvertently missing the exhibits. Other than attaching the missing the exhibits, this document is identical to
`what was filed on April 7, 2025.
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`Douglas P. Wilson (the “Receiver”) hereby submits this Receiver’s Initial Inventory
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`and First Monthly Report (the “Report”) in accordance with the Order Appointing Receiver
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`(the “Order of Appointment”) dated March 6, 2025, and entered in the above-entitled matter.
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`This Report is organized into the following four sections: I. Appointment Information, II.
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`Initial Inventory, III. Receiver’s Activities, and IV. Accounting and Fees.
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`I.
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`APPOINTMENT INFORMATION
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`1.
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`Appointment of the Receiver
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`On March 6, 2025 the Superior Court of California, County of San Francisco ordered the
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`appointment of Douglas P. Wilson as Receiver over the real property commonly known as
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`Parkmerced, a 152 acre residential community containing over 3,000 residences in San Francisco,
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`California (the “Property”) and Plaintiff’s personal property collateral related thereto (Defendant’s
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`real, personal, tangible, and intangible property, together with any and all other property that
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`secures the loan, the “Receivership Estate”). The Court appointed the Receiver to take possession
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`of, control and manage the Property and Receivership Estate as further outlined in the Order of
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`Appointment. The appointment of the Receiver was stipulated to by both the Plaintiff and
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`Defendants (the “Parties”).
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`2.
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`Receiver’s Oath and Bond
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`In accordance with the Order of Appointment, the Receiver signed his oath and obtained a
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`bond in the amount of $20,000.00, the originals of which were filed with the Court on March 9 and
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`March 10, 2025, respectively.
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`3.
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`Background and Purpose of the Receivership
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`On February 20, 2025, Plaintiff Wells Fargo Bank, National Association, Solely in its
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`Capacity as Trustee in Trust for Holders of MRCD 2019-Park Mortgage Trust, Commercial
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`Mortgage Pass-Through Certificates, Series 2019-Park, (“Plaintiff”) filed a complaint against
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`Parkmerced Owner LLC (“Defendant”). In the complaint, Plaintiff alleged that Defendant had
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`defaulted on its $1,500,000,000.00 loan as, pursuant to the loan agreement, the loan matured,
`
`/ / /
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`/ / /
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`SMRH:4919-8198-0211.2
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`became payable in full on December 9, 2024, and Defendant had failed to pay the debt.
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`Shortly after Plaintiff filed its Complaint, both Plaintiff and Defendant stipulated to the
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`appointment of a receiver to take control of the Property, whereupon this Court entered the Order
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`of Appointment on March 6, 2025.
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`The purpose of the Receivership is for the Receiver to take over complete control and
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`management of the Property’s operations and financials. This includes the Receiver taking
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`possession of, operating, leasing, managing, controlling and conducting the Property and its
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`associated business and incurring the expenses necessary for the same, and doing all things and
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`incurring the risks and obligations ordinarily incurred by owners, managers, and operators of
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`similar properties, provide that no such risks or obligations so incurred shall be the personal risk or
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`obligation of the Receiver, but shall be a risk or obligation of the Receivership Estate.
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`Paragraph 4 of the Order of Appointment provides that: “Within 30 days of taking control
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`and possession under this Order, the Receiver shall file an inventory itemizing all personal property
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`of which he has taken control or possession and shall promptly file supplemental inventories of any
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`material personal property subsequently coming into the Receivership Estate.”
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`Paragraph 19 of the Order of Appointment provides that: “The Receiver shall prepare, on a
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`monthly basis beginning 30 days after his appointment and for so long as the Subject Property shall
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`remain in his possession or care, reports setting forth all receipts and disbursements, cash flow,
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`changes in the assets in his charge, claims against the assets in his charge, and other relevant
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`operational issues that have occurred during the preceding month.”
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`II.
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`INITIAL INVENTORY
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`4.
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`Introduction and Limitations
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`This project involves a large and intricate apartment complex that was originally developed
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`over eighty years ago and currently encompasses 3,165 units and approximately 8,000 residents.
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`The Receiver and his team have diligently taken steps to, pursuant to the Order of Appointment,
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`assert control and oversee all operational and financial aspects of the Property. Notwithstanding
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`the significant amount of work already performed to date – as will be further detailed in this Report
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`– there will naturally be an elongated onboarding process with a project this size.
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`SMRH:4919-8198-0211.2
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`During the initial weeks of the Receivership, financial and operational control of the
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`Property were successfully transitioned to the Receiver. Bank signatories and authorizations were
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`transferred to the exclusive control of the Receiver and his team, and proper reporting protocols
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`and initial management systems were established. The Receiver continues to gather, review, and
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`process new information about the Property daily to assimilate a holistic understanding.
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`Importantly, however, given that this process remains ongoing, information contained within this
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`Report is still preliminary and subject to change as new information becomes available. The
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`Receiver continues to communicate closely with both Parties and additional updates will be
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`provided in subsequent reports.
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`5.
`
`General Property Description
`
`This receivership revolves around the largest apartment complex in San Francisco and one
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`of the largest in the United States. Spanning across 152 acres, Parkmerced contains 3,165
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`apartment units housing approximately 8,000 residents. Originally built between 1941 and 1951,
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`the Property nestles up against Lake Merced, San Francisco Golf Club, and TPC Harding Park on
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`the Southern and Western sides. To the North lies San Francisco State University and to the East
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`borders Ingleside. The views and location offered by the Property are exceptional and unique.
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`Balancing this, the Property is also over eighty (80) years old in some areas. As will be described
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`further in this Report, the Property’s age shows with significant deferred maintenance. While the
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`below makes an attempt to properly describe and encapsulate the vast property, due to its breadth
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`and detail, this remains a tall order. To assist in describing the Property, attached as Exhibit “A”
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`are photos taken of the Property by the Receiver and his team during their many visits, which
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`provide additional context and detail.
`
`a.
`
`Property Layout and Unit Mix
`
`The Property is comprised of two main building types: high-rise apartment towers and two-
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`story townhomes. Each of the eleven (11) high-rise towers are thirteen-stories tall (including
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`basement levels) and comprise of 153 units each—or a total of 1,683. The high-rise towers are
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`loosely grouped around three areas: five in the southwest corner of the Property, two in the
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`northwest corner and the last four located just west of Juan Bautista Circle—a central grassy oval
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`SMRH:4919-8198-0211.2
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`in the middle of the Property.
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`The remainder of the Property is primarily comprised of townhomes, of which there are
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`1,468 units1 further divided into “garden” and “patio” style buildings. Most of the townhomes tend
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`to be grouped in “U” shaped buildings that circle around a communal garden or green space. There
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`is significant street parking throughout as well as covered car ports attached to each townhome
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`building.
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`There are 1-bedroom, 2-bedroom and 3-bedroom options in both the high-rises and
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`townhomes. Studio units are available only in the high-rise towers. Rental rates for all units range
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`from approximately $2,796 to $5,554 per month, depending on unit type and bedroom size. The
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`table below provides a detailed breakdown of the unit mix between high-rise tower units and
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`townhome units.2
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`Unit Type
`
`# Units Avg. SF
`
`1
`2
`3
`4
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`5
`
`Studio Tower
`1x1 Tower
`2x2 Tower
`3x3 Tower
`Tower Unit Subtotal
`1x1 Townhome
`2x1 Townhome
`3x2 Townhome
`3x2.5 Townhome
`Townhome Unit Subtotal
`10
`11 Total/Wtd. Average
`
`6
`7
`8
`9
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`11
`571
`120
`95
`797
`1,871
`281
`42
`43
`2,237
`3,831
`
`521
`789
`698
`1,083
`806
`996
`1,136
`1,401
`1,415
`1,029
`936
`
`b.
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`Amenities
`
`The Property offers amenities featuring green spaces, parks, playgrounds, volleyball &
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`tennis courts, community fitness centers, leasing office, onsite laundry, gardening, and walking
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`trails. Parkmerced is well-connected to nearby parks, public transportation, and golf courses. Also
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`1 There are additional “Phase 1” units included within the property commonly referred to as
`“Parkmerced” and included in the Vision Plan (discussed further in this Report), however, the
`Receiver is informed these are not a part of the Plaintiff’s collateral and therefore not a part of the
`Receivership Estate.
`2 As a key to the table, a “1x1” refers to a 1 bedroom, 1 bath unit. A “2x1” refers to a 2 bedroom,
`1 bath unit. A “2x2” refers to a 2 bedroom, 2 bath unit. Etcetera.
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`SMRH:4919-8198-0211.2
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`located within Parkmerced is The Montessori Children’s School—a preschool founded in 1976.
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`Although the school is currently closed, plans are underway to reopen in the near term.
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`c.
`
`Brief History of the Property
`
`To provide a helpful backdrop to this Report, the following will provide a brief history of
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`the Property. Parkmerced was originally developed in the early 1940s by the Metropolitan Life
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`Insurance Company. Designed to accommodate middle-income families, especially veterans
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`returning from World War II and the Korean War, the community was built with the vision of
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`providing quality housing in a suburban style setting within the city. The development continued
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`through the 1950s, creating a unique blend of residential and park-like environments. Parkmerced’s
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`unusual pie-shaped blocks were designed by its architect, Leonard Schultze, and share many
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`features with his Park La Brea design.
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`In 2005, a small but notable transaction occurred when Carmel Companies sold 153 units
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`of Parkmerced to neighboring San Francisco State University for $20 million. This sale aimed to
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`provide housing for students and faculty, strengthening the connection between the complex and
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`the nearby university.
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`In 2019, the Defendant purchased the Property with plans to significantly expand it by
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`increasing the number of units from 3,165 to approximately 8,900 in total. This was a part of the
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`Vision Plan which is further described later in this Report. However, these plans – approved in
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`2011 – have been stalled for some time after encountering various impediments.
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`6.
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`Personal Property
`
` Attached as Exhibit “B” is an itemized list of personal property that is a part of the
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`Receivership Estate and includes items such as vehicles, forklifts and other equipment. This list
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`was prepared with the assistance of the existing onsite property management team.
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`7.
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`Condition of the Property
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`The Receiver and his team performed their initial takeover and on-site evaluation between
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`March 11 and March 13, 2025. As will be further discussed in the Deferred Maintenance section
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`of this report, there is significant and ubiquitous deferred maintenance issues throughout the
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`Property. Many of these are visually apparent and negatively impact safety, attractiveness and
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`SMRH:4919-8198-0211.2
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`value. From the exterior there are notable damaged structures, visible dry rot, peeling paint, and
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`unmaintained parks. From the interior, many of the units consist of the same flooring, electrical
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`and cabinetry from the 1940’s and 50’s. Further, due to financial constraints, many issues that arise
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`at the Property have been addressed with “band-aids”—remedies that solve the problem only
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`superficially and temporarily before additional repair work is required. To assist with illustrating
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`some of the deferred maintenance issues, Exhibit “C” incorporates photos and descriptions of a
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`small sample.
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`The lack of amenities, mixed with a limited sense of arrival and tired appearance, have
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`contributed to a steady decline at the Property. Further underscoring the detrimental issues facing
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`the Property, as of the time of the Receiver’s appointment, there were only approximately sixty-
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`eight (68) vacant unrented units readily available to rent, and a further 483 units that were classified
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`as “vacant unrented not ready,” meaning additional cleaning, repairs and preparation of varying
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`degrees were needed to bring the units on the market. While sixty-eight (68) units may seem
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`sufficient, when spread across the eight (8) different unit types and other important factors, this
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`becomes a bottleneck to ensuring an accelerated lease up of the Property.
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`In general, however, the Property is a viable community and has many unique and
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`impressive attributes including location, spacious streets, views and history. The property consists
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`of a vast amount of open space available to tenants and community members to enjoy, but will
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`require significant attention and investment.
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`III. THE RECEIVER’S ACTIVITY
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`8.
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`Introduction
`
`As is described throughout this Report, the Receiver has observed and is further informed
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`of significant deferred maintenance throughout the Property—the magnitude of which is difficult
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`to overstate. In some parts, the Property is over eighty years old and is visually apparent.
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`Compounding this attribute, the typical historical repairs appear to have been “band-aids”—
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`addressing symptoms as opposed to root causes. While this approach is less expensive in the short
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`term, it typically generates larger and costlier repairs in the future. Many of these band-aid repairs
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`are coming to their natural term and require a more comprehensive resolution. Therefore, the
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`SMRH:4919-8198-0211.2
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`Receiver has made it a priority to move forward with quickly addressing the deferred maintenance,
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`capital expenditure, and life safety issues so that the Property can be positioned for better
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`performance and appearance. The Receiver is proceeding with a sense of urgency as the peak
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`leasing season is approaching.
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`9.
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`Initial Onsite Meetings and Transition to the Receiver
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`On March 11, 2025, the Receiver and his team made an initial onsite visit with Maximus
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`Real Estate, VPM General Building, and representatives from Planned Companies to formally
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`transfer control of the Property over to the Receiver. Three all-day meetings – the first of many –
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`were conducted with these groups to provide in-depth discussions regarding the Property’s
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`operations, status and condition. Further, the Receiver and his team walked each group through
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`the receivership process (distributing copies of the Order of Appointment), its legal framework,
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`delegation of responsibilities, and outlining expectations. The discussion also focused on key
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`operational challenges including severe deferred maintenance and life safety issues – mold, roof
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`leaks, structural deterioration, and non-operational elevators – alongside the historical financial
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`distress and opportunities to improve the Property.
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`Leasing and staffing were also major topics. The Receiver is informed occupancy stands at
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`82% – below the local average of 88–89% – with significant engagement with rent-controlled
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`tenants and Section 8 voucher holders. A sharp post-COVID decline in student residents reportedly
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`added to leasing challenges. The Receiver emphasized the need to regain public trust and
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`underscored the goal of quickly addressing the deferred maintenance and life safety issues with a
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`sense of urgency which will assist with increasing occupancy.
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`The Receiver and his team toured the Property visiting units in both the high-rise towers
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`and townhomes, staged units, recently vacated (but not yet turned) units, units turned and ready for
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`occupancy, the available amenities, maintenance offices, leasing offices, areas acutely in need of
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`repairs, and units with fire, dry rot and other damage.
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`Lastly, the Receiver and his team met individually with the teams overseeing accounting,
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`IT, human resources, legal, maintenance, property management, and security. Over the course of
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`the following few weeks, numerous additional onsite (as well as offsite) meetings took place
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`SMRH:4919-8198-0211.2
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`between the Receiver, his team, and the existing property management team discussed below.
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`10.
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`Existing Property Management
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`The Property is currently managed by three companies: Maximus Real Estate Partners,
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`LLC, VPM General Building, LLC and Planned Companies. Maximus and VPM are affiliates of
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`the Defendants. The below will provide a summary of each of these entities and their role within
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`the current property management structure.
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`a.
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`Maximus Real Estate Partners (“Maximus”)
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`Maximus acts as the primary property manager and asset oversight group for Parkmerced.
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`Its responsibilities include financial operations, leasing strategy, legal compliance, government
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`affairs, public relations, and resident communications. Maximus employs approximately forty-
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`seven (47) staff members dedicated to the Property, spanning leadership roles in operations,
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`finance, legal, leasing, marketing, and human resources. Maximus also leads resident engagement
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`efforts through a resident advocacy committee and handles relationships with city officials and
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`agencies. It was also a key decision-maker during the redevelopment and entitlement phases.
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`Following a thorough review, it was confirmed that several employees of Maximus allocate their
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`time not just to the Property, but also to the future development phases as well.
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`b.
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`VPM General Building LLC (“VPM”)
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`VPM General Building is responsible for maintenance and physical operations of the
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`property. As a ‘dba’ of VPM Maintenance, the company manages sixty-four (64) employees – some
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`of whom are unionized – and handle critical infrastructure needs like repairs, system maintenance,
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`and general upkeep. VPM staff are essential in managing health and safety issues flagged during
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`the property tour. VPM serves as the operational backbone ensuring the property’s habitability and
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`maintenance response across its vast footprint. VPM also engages with three existing unions:
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`Plumbers Local 38, Painters Local 16, and Landscapers Local 261. The unions have been involved
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`with the project for many years and the Receiver’s goal is to maintain them in place. Each of the
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`respective unions’ contracts are current with 2-3 years of term remaining.
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`c.
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`Planned Companies
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`Planned Companies serves as the third-party janitorial contractor for the Property. Their
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`SMRH:4919-8198-0211.2
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`staff of forty-one (41) employees are non-union and are responsible for the daily cleaning and
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`upkeep of common areas, residential towers, and amenity spaces. While not heavily involved in
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`strategic operations, their role is crucial in maintaining cleanliness, hygiene, and supporting the
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`Property's overall livability. Planned Companies’ performance directly affects resident satisfaction
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`and leasing appeal.
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`11.
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`Evaluation of Property Management Candidates
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`Paragraph 5 of the Order of Appointment establishes that, at any time after 60 days, the
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`Receiver may, in the exercise of his business judgment, terminate the contract with VPM. To ensure
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`the Receiver is properly fulfilling his duties, the Receiver has begun the process of evaluating the
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`current property management and structure, as well as third-party property management candidates
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`to determine how the Property would best be served.
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`The Receiver compiled a list of the top property managers in the area including Sares Regis,
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`Greystar, Ballast, Veritas and Mission Rock. A thorough review was performed on each candidate
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`to vet their capabilities and experience. As part of the process, the Receiver interviewed each
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`candidate – in many cases multiple times – and requested they submit their typical brochures, CV’s
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`of their leadership team, an organizational chart of the team that would be working on the project,
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`case studies, information regarding their experience with similar properties, details covering their
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`presence in the Bay Area, number of units currently being managed, experience with labor unions,
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`experience with value-add projects, and a request they design and submit a property transition plan
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`unique to the Property for the Receiver’s review.
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`Following this comprehensive review – which included, among other items, an analysis of
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`their experience, capabilities and, importantly, their ability to strategically revitalize a substantially
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`large value-add property – the Receiver has made a preliminary determination of who would be the
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`best management firm to engage. We are in the process of completing our due diligence and
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`contractual arrangement with them in the next week. We will disclose the name of the firm in our
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`next report to the court after this important process is completed. Over the course of the coming
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`weeks, and no sooner than May 5, 2025 (60 days from the Order of Appointment), the Receiver
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`will be working with the new property management firm, Maximus, VPM, and Planned Companies
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`SMRH:4919-8198-0211.2
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`to strategically design and implement a plan to transition property management duties over to the
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`new property management company. The transition plan will focus on limiting disruption and
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`effectively addressing deferred maintenance issues of the Property.
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`12.
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`Deferred Maintenance
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`As of the initial takeover, the Receiver and his team have been focused on a complete review
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`of the deferred maintenance needs of the Property. The Receiver has identified significant deferred
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`maintenance that needs to be addressed and has categorized them into the following five categories:
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`1) Life Health Safety, 2) City Code Requirements and Fire Department Violations, 3) Short-and
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`Long-Term Deferred Maintenance, 4) Equipment Needs and 5) Turn of Units. While the following
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`will provide a broad overview of these categories, the Receiver intends to work closely with the
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`new property management firm and the existing teams to develop a course of action addressing
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`these issues, establishing their costs, and designing a schedule of improvements. However, while
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`this plan is developed, the Receiver intends to immediately utilize the $500,000 authorized by the
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`Order of Appointment to primarily address life-safety and city and fire violation issues, while
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`secondarily balancing the need for the necessary continued turn of units to continue to increase
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`leasing.
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`The below will provide a limited summary of deferred maintenance issues identified and
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`confirmed by the Receiver and his team:
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`Life and Safety:
` Damaged Sidewalks – trip and fall hazards
` Replacement of railings
` Landscape intruding on structures
` Pollution (Mold) analysis and survey of reported issues
` Dry Rot occurring in failing carports and porches/ entries to units
` Water intrusion within units due to lack of roof maintenance and updated gutters
` Elevator operations (currently 3 down of 22 in 11 towers)
`
`Interior tower corridor lighting
` Security cameras and access control systems
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`City and Fire Code:
` Replacement of fire doors in the towers
` Replacement of tower fire hoses, pumps and risers
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`SMRH:4919-8198-0211.2
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` Noted roughly 22 City Violations to be addressed and/ or are process, receivership
`team is tracking
` Façade Inspections per AB110 Requirements
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`Short-and Long-Term Deferred Maintenance:
` Replace hot water heaters in towers
` Replace steam heaters in towers
` Window replacement in towers (roughly 50%) more may be advantageous and more
`economical when coupled with façade improvements
` Failing of exterior water proofing on towers
` Replacement of extractor fans for towers
` Replace booster, pumps and water containment tanks for townhomes – central
`plants.
` Tile roofing on townhomes – algae treatment for initial issues. Study replacement
`of tile roofs.
` Landscape improvements
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`Equipment Needs for Operations:
` Trash Cars
` Compactors
` Landscape Equipment to maintain the property
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`The Receiver has also identified the lack of available units ready for lease as a significant
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`chokepoint to lease up. At an average of roughly $4,500 in total costs to turn a unit (limited to
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`cleaning, paint and flooring), the Receiver has authorized the current property management team
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`to immediately implement a turn of approximately 50+ units.
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`13.
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`Banking
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`One of the Receiver’s top priorities was to gain control of the Property’s bank accounts. To
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`this end, the Receiver transitioned signature control of the five (5) bank accounts at JP Morgan
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`Chase held under the name Parkmerced Owner, LLC. The Receiver is maintaining the general cash
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`management procedures instituted by Defendants and Plaintiff pre-receivership. This is further
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`discussed in the accounting section below.
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`14.
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`Insurance
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`The Receiver obtained copies of the insurance policies and has been added as an additional
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`insured on all policies. The Property uses Lockton Companies – the world’s largest privately held
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`insurance brokerage firm – as its insurance broker to manage its insurance needs. The Receiver’s
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`team has had multiple meetings and conversations with Lockton to gain an understanding of the
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`Property’s current coverage, any gaps that may exist, and any outstanding claims.
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`15.
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`The Vision Plan
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`a.
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`Description of the Parkmerced Vision Plan
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`The Parkmerced Vision Plan (the “Vision Plan”) was developed to transform the existing
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`property from an aging development of 3,165 units to a vibrant, holistic community consisting of
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`5,679 net new residential units, one-for-one replacement of existing 1,538 rent-controlled units,
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`310,000 square feet of commercial use, 64,000 square feet of recreational/fitness center/community
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`center use, 100,000 square feet of building and property maintenance use, 25,000 square feet of
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`educational use, and net new off-street parking for up to 6,252 vehicles. The Vision Plan was slated
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`to be implemented over the course of approximately 20-30 years.
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`The Vision Plan also includes public benefit requirements such as the construction of two
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`new transit stations, the relocation of an existing transit station, improvement and reconfiguration
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`of streets and intersections to improve access, reconfiguration of the existing open spaces to provide
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`more usable open spaces, including a new park, athletic fields, an organic farm, walking and
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`bicycling paths, and community gardens. It would also replace typical gutters and storm drains by
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`providing for a network of bioswales and bio-gutters.
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`b.
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`Current Status of the Vision Plan
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`Working closely with the City, the Vision Plan has undergone its initial environmental
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`review, and execution of the Development Agreement between the City and County of San
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`Francisco and Parkmerced Investors Properties, LLC, the Developer entity of the Vision Plan. The
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`Development Agreement was approved by the City of San Francisco in 2011. The Vision Plan
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`includes specific governing documents such as Design Standards and Guidelines, Sustainability
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`Plan, Transportation Plan, and Infrastructure Report. These documents can be found on the San
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`Francisco Planning Departments website: https://sfplanning.org/project/parkmerced#info.
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`c.
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`Next Steps
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`The Vision Plan is a complex, long-term redevelopment plan for the Parkmerced
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`community. The Receiver is currently evaluating the status of the plan and will report its analysis
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`SMRH:4919-8198-0211.2
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`and suggested next steps (as applicable) in future reports.
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`IV. ACCOUNTING AND FEES AND COSTS
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`16.
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`Budget and Funding
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`The Receiver and his team are preparing a comprehensive budget of anticipated monthly
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`operating, capital and administrative expenses. The Order of Appointment directs the Receiver to
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`prepare and share a budget with the Plaintiff within 45-days of his appointment—which is April
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`21, 2025.
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`The original 2025 operating budget prepared by Maximus reflects an average monthly net
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`loss of about $1,000,000. The first quarter of 2025 has a net loss of over $5,400,000. While these
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`budgets will need to be updated by the Receiver, it is clear that additional funding will be needed
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`to fund operations, capital and administrative expenses, and to address the litany of deferred
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`maintenance issues.
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`17.
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`Accounting
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`The Receiver has taken over control of the five (5) bank accounts held at JP Morgan Chase,
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`under the name the Defendant. The Receiver has removed all previous signors and has added his
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`team onto the account as signers. The Receiver has full online access to all bank accounts and
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`monitors the accounts daily to confirm transactions were authorized and approved by the Receiver.
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`As of the time of this writing, the March financials for the Property have not yet been
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`completed. Details of March financials will be incorporated in the next report.
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`18.
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`Fees and Costs
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`Attached as Exhibit “D” are copies of the Receiver’s billing statements for the months of
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`January ($4,107.00), February ($12,882.50) and March ($189,891.69). These billing statements
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`include time for services rendered and expense