Judgment and Financial Assets for Sale

Sale of judgment and remnant assets which includes:

1. Koupaei Judgment: The rights and interests in and to that certain Judgment against Esmat Mohseni Koupaei, Adv. Proc. No. 21-80068 [Adv. Dkt. 53], and related proceeds.
2. Remnant Assets: All known or unknown assets or claims of the above-captioned Bankruptcy Estate, which have not been previously sold, assigned, or transferred, subject to the following specific exclusions:
   The following are specifically excluded from the sale: (a) cash held in the Trustee's fiduciary bank accounts for the Seller's case, held at Webster Bank ending in -6667 and -7938; (b) any funds held in the trust account of the Trustee's attorney, Christine Brimm and/or Barton Brimm, PA, in connection with the Seller's case; (c) any tax refunds owed to the Bankruptcy Estate in connection with state and/or federal income tax returns filed by the Trustee during the pendency of the Bankruptcy case for tax years 2019, 2020, 2021, 2022, and/or 2023; (d) the books and records used by the Seller in the ordinary course of business, but excluding any recent statements, notices or correspondence received by the Trustee relating to assets specifically acquired in this sale; (e) any assets exempted by the Seller pursuant to 11 U.S.C. § 522; (f) the Koupaei Judgment and any proceeds from the sale of such judgment; and (g) the proceeds from the sale of the Remnant Assets;