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UNITED STATES BANKRUPTCY COURT
NORTHERN DISTRICT OF NEW YORK
____________________________________________
VWP, Inc. Case No.13-60282
Chapter 11
Debtor.
____________________________________________
Debtors Response To Motion BY Creditor To Modify The Automatic
Stay Pursuant to Section 362(a)
The debtor through its attorney does hereby appear and allege as
follows:
1. The debtor filed for relief under chapter 11 of the bankruptcy
code on February 36, 2013.
2. The debtor is a company that holds two pieces of real estate
that were damaged in the flood following Hurricane Irene.
3. The debtors parent corporation operated a Volkswagen parts
business using the properties as part of its continuing business.
4. The Debtors principal place the two properties owned by the
debtor into the FEMA Hazard Mitigation Grant Program. The program
is designed to remove properties from private use for a public
purpose.
5. The letter attached dated December 21, 2012 form Delaware County
Chief Planner indicates that 102 Depot Street is part of the Grant
program and scheduled for an appraisal to determine the amount to
be paid by the government for the purchase of the property.
6. The letter dated November 27, 2012 indicates that the purchase
price will be based on the fair market value pre-flood condition.
7. The debtor, therefore, is in a position to obtain a purchase
price for the property which exceeds the current value of the flood
damaged property without regard to the future condition of the
property or the future market price.
Accordingly the debtor requests that the relief requested be
denied.
Dated: April 18, 2013
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/s/ Richard Croak
__________________
Richard Croak
Attorney For Debtor
314 Great Oaks Blvd.
Albany, NY 12203
Tel 518-690-4410
fax 518-690-4435
rcroak@richardcroak.com
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