Robert M. Marino, Esq. VSB #26076 

Redmon Peyton & Braswell, LLP 

510 King Street, Suite 301 

Alexandria, VA 22314 

703-684-2000 

703-684-5109 (fax) 

rmmarino@rpb-law.com

Counsel for Blue Ridge Arsenal, Inc. 

IN THE UNITED STATES BANKRUPTCY COURT 

FOR THE EASTERN DISTRICT OF VIRGINIA 

Alexandria Division 

 

 ) 

In re: ) Case No. 18-10472-KHK 

Blue Ridge Arsenal, Inc., ) Chapter 11 

 Debtor. ) 

 ) 

NOTICE OF MOTION MOTION TO APPROVE SALE OF ASSETS FREE AND CLEAR 

OF ALL LIENS, CLAIMS ENCUMBRANCES AND INTERESTS 

Blue Ridge Arsenal, Inc. (“Debtor”), the Debtor and Debtor-In-Possession herein, by and 

through the undersigned counsel, has filed papers (specifically that certain Motion to Approve 

Sale of Assets Free and Clear of All Liens, Claims, Encumbrances and Interests (the “Motion”)) 

requesting the entry of an Order (i) approving the terms and conditions of that certain Agreement 

of Sale and Purchase (the “Sale Agreement”) by and between, inter alia, the Debtor, as seller, 

and Blackfish Armory, LLC (“Blackfish”), a Virginia limited liability company and a secured 

creditor holding senior lien on all assets of the Debtor, as purchaser, providing for the sale of 

substantially all of the Debtor’s assets in exchange for payment of the sum of $600,000 through 

crediting of the current amount owed to Blackfish as a secured creditor ($600,000), and by 

payment of the sum of $25,000 in cash, as more particularly described in the Motion, and 

(ii) authorizing the sale of said property to Blackfish, free and clear of all liens, claims, 

encumbrances, and interests, including the liens, claims, encumbrances and interests of certain 

creditors more particularly described in the Motion. A copy of the Motion, with Exhibit and a 

proposed Order, is being served on all known lien creditors and is available to any other party 

upon written request to the undersigned counsel. Regardless, all pleadings and exhibits have 

been filed with the Court and are available for review through the Bankruptcy Court’s website at 

https://www.vaeb.uscourts.gov. 

Your rights may be affected. You should read these papers carefully and discuss 

them with your attorney, if you have one in this bankruptcy case. (If you do not have an 

attorney, you may wish to consult one.) 

If you do not wish the court to grant the relief sought in the Motion, or if you want the 

court to consider your views on the Motion, then you or your attorney must: 

 On or before 5:00 p.m. on February 5, 2019 (the “Response Deadline”) file with 

the Court, at the following address, Clerk of Court, United States Bankruptcy Court 

for the Eastern District of Virginia, Alexandria Division, 200 South Washington 

Street, Alexandria, Virginia 22314, a written response with supporting Memorandum, 

as required by Local Rule 9013-1(H). Unless a written response and memorandum 

is filed and served by the Response Deadline, the Court may deem any opposition 

waived, treat the Motion as conceded, and issue an order granting the requested 

relief without further notice or hearing. If you mail your response to the Court for 

filing, you must mail it early enough so the court will receive it on or before the date 

noted above. You must also mail a copy to the persons listed below. 

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 Send a copy of any written response to the following persons: 

Robert M. Marino, Esq. 

Redmon Peyton & Braswell LLP 

 510 King Street, Suite 301 

Alexandria, Virginia 22314 

The Office of the United States Trustee, Region 4 

115 South Union Street, Suite 210 

Alexandria, VA 22314 

 Attend a hearing presently scheduled for Tuesday, February 12, 2019, at 11:00 

A.M., before the Honorable Klinette H. Kindred, United States Bankruptcy Judge, 

Courtroom II, Second Floor, 200 South Washington Street, Alexandria, Virginia 

22314. 

If you or your attorney do not take these steps, the court may decide that you do not 

oppose the relief sought in the Motion and may enter an order granting that relief. 

Dated: January 4, 2019 Respectfully Submitted, 

/s/ Robert M. Marino 

Robert M. Marino, Esq. VSB#26076 

REDMON, PEYTON & BRASWELL, LLP 

510 King Street, Suite 301 

Alexandria, VA 22314 

Phone: 703-684-2000 

Fax: 703-684-5109 

Email: rmmarino@rpb-law.com

Counsel for Blue Ridge Arsenal, Inc. 

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CERTIFICATE OF SERVICE

I hereby certify that I have this 4th day of January, 2019, caused a copy of the foregoing Notice to be served 

electronically through the electronic case filing system to all persons entering their appearance and requesting notice 

in this case, and by first class mail, postage prepaid, to all persons on the attached mailing matrix. And by certified 

mail to the following persons believed to hold liens of record on the subject Assets: 

Sandy Spring Bank 

c/o CT Corporation System 

4701 Cox Road, Suite 285 

Glen Allen VA 23060 

Sandy Spring Bancorp, Inc. 

17801 Georgia Avenue 

Olney, MD 20832 

Attn: Ronald E. Kuykendall, Executive Vice President, General Counsel and Secretary 

American Express National Bank f/k/a American Express Bank, FSB

Attn: Laureen E. Seeger, Executive Vice President and General Counsel 

4315 South 2700 West 

Salt Lake City, UT 84184 

Wells Fargo Financial Leasing, Inc. 

c/o Corporation Service Company 

100 Shockoe Slip, 2nd Floor 

Richmond, VA 23219 

Wells Fargo Financial Leasing, Inc. 

800 Walnut Street 

Des Moines, IA 50309 

Attn: C. Allen Parker, Senior Executive Vice President and General Counsel 

Monroe Capital Management Advisors, LLC 

311 South Wacker Drive 

64th Floor 

Chicago, IL 60606 

Attn: Peter Gruszka, General Counsel and Managing Director 

Channel Partners Capital, LLC 

11100 Wayzata Blvd., Suite 305 

Minnetonka, MN 55305 

Attn: Brad Peterson, CEO 

CT Corporation System, as Representative 

330 N. Brand Blvd., Suite 700 

Glendale, CA 91203 

Attn: SPRS 

/s/ Robert M. Marino 

Robert M. Marino 

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