IN THE UNITED STATES BANKRUPTCY COURT

FOR THE EASTERN DISTRICT OF VIRGINIA

Alexandria Division

In Re: :

 :

ALSTRAW ENTERPRISES, Inc. : CASE NO 18-11430-BFK

 : Chapter 11 

 Debtor :

 :

MOTION TO SELL ASSETS OF THE DEBTOR

COMES NOW the debtor, Alstraw Enterprises, Inc., by counsel,

and pursuant to 11 U.S.C. 363(b) moves this Court for the entry

of an Order authorizing the sale of certain assets of the debtor,

and in support thereof it states as follows: 

1. The debtor corporation operates four coin laundries at

separate locations, including Dulles Park, Herndon, Dumfries and

Manassas. Each of these businesses occupy leased space and some

have different names under which they do business. The Dumfries

location is known as “Plaza Coin Laundry”, Herndon is known as

the “The Herndon Coin Laundry”, and the Manassas location is

known as “Don’s Wash”.

2. Stephen Karbelk of Auction Markets, LLC was appointed as

a sales agent for the debtor by an order of this Court entered on

July 12, 2018.

3. Scott W. Miller of Analytic Financial Group, LLC was

appointed as a financial advisor for the debtor retroactively to

June 15, 2018, by an order of this Court entered on July 17,

2018.

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4. After a commercially reasonable advertising campaign by

Auction Markets, LLC, which included the preparation of financial

information by the Analytic Financial Group for the purpose of

providing prospective buyers with reliable financial data related

to each specific location, the debtor has received an offer for

the purchase of the Dumfries and Herndon businesses from Jennifer

Eubanks (hereafter Eubanks), which includes payment of $60,000.00

for the Dumfries location and $100,000.00 for the Herndon

location. These offers are severable, meaning that both or any

one separately may be approved, but should one offer not be

approved for any reason, the remaining offer may be.

5. After the Eubanks offer for the Dumfries and Herndon

locations was received, and a Motion and Notice was filed asking

for its approval, a second offer was received from Nilraj

Chudasama for all three locations, including an offer of

$66,000.00 for the Dumfries location, $110,000.00 for the Herndon

location, and $93,000.00 for the Manassas location. A copy of

this offer in the form of an Asset Purchase Agreement is attached

as an exhibit. 

6. The Asset Purchase Agreement contemplates the

assignment of all leasehold rights, and sale of all of the

debtor’s assets, tangible and intangible, at the Dumfries,

Manassas, and Herndon locations, including, but not limited to,

washing machines, dryers, coin machines, vending machines,

fixtures and the like, in addition to the debtor’s good will and

business name associated with the Herndon, Manassas, and Dumfries

locations. These offers are severable, meaning that all of them,

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or any one separately may be approved, but should one offer not

be approved for any reason, the remaining offer(s) may be.

7. The debtor’s principal, Arjen Weiss, and not the debtor

Alstraw, is the tenant on the leases for the Dumfries and the

Manassas locations. Mr. Weiss will cooperate and do all that may

be necessary to transfer his lease rights to the buyer. However,

The Asset Purchase Agreement is subject to a number of

contingencies, including an acceptance of the buyer by the

landlord for each location, including the Dumfries and Manassas

locations.

8. The leases for the Herndon, and Manassas locations are

in arrears. The lease arrearage for the Manassas location is,

upon information and belief, in excess of $83,000.00. 

9. Under the terms of Mr. Karbelk’s employment, he is

entitled to a 10% commission paid at settlement on all assets

sold through his efforts, and the recovery of marketing expenses

of up to $3,000.00 for each sale. The commission on this sale

would be split between Stephen Karbelk/Auction Markets, LLC, the

estate’s agent, and Horizon Business Brokers, LLC, the buyer’s

agent. At the same time, it is anticipated that not more than

$3,000.00 in expenses for professional photographs, DropBox Due

Diligence Room, and Constant Contact email marketing will be

payable on this sale to Auction Markets, LLC at the time of

closing.

10. To the extent that funds are available, any lease

arrearage for any of the locations would be cured at the time of

settlement on the sale of that location.

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11. There are no liens against the debtor, nor any

encumbrances on the assets to be sold under the Asset Purchase

Agreement. 

12. The debtor cannot operate the Herndon, Manassas, or

Dumfries locations profitably, and their sale would reduce its

operating loss and provide it funds which will enable it to file

a Plan of Reorganization.

13. The debtor submits that, at the time this motion is

filed, the Chudasama offer and Asset Purchase Agreement

represents the best price obtainable for these assets, and the

best result for the estate and the creditors at this time.

WHEREFORE the debtor prays that this Court enter an order

approving the sale of all assets of the debtor associated with

the Manassas location (Don’s Wash) in accordance with the

attached Asset Purchase Agreement, and determine which of the two

offers for the Herndon location (The Herndon Coin Laundry) and

the Dumfries Location (Plaza Coin Laundry) benefits the estate

best, and that the 10% commission due Auction Markets, LLC and

the brokers, and Auction Market LLC’s expenses up to $3,000.00 be

paid at settlement, and for such other relief as may be needed.

 Alstraw Enterprises, Inc

 By counsel

/s/ Richard G. Hall

Richard G. Hall, Esquire

Counsel for the debtor

7369 McWhorter Place, Suite 412

Annandale, Virginia, 22003

(703) 256-7159, VA Bar No 18076

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 CERTIFICATE OF SERVICE

I hereby certify that on August 15, 2018, a true copy of

this Motion was mailed to The Richmond Corporation at 1093 Seven

Locks Road, Rockville, MD 20854, and to all parties on the

attached service list, and also served on the United States

Trustee via ECF.

 /s/ Richard G. Hall

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