Bradley D. Jones (VSB No. 85095) 

Counsel for Trustee

ODIN FELDMAN & PITTLEMAN PC

1775 Wiehle Avenue, Suite 400

Reston, Virginia 20190

Phone: 703-218-2176

Fax: 703-218-2160

Brad.Jones@ofplaw.com Page 1 of 3

UNITED STATES BANKRUPTCY COURT

FOR THE EASTERN DISTRICT OF VIRGINIA

Alexandria Division

In re: *

*

Kareem Mohamad Shoura, * Case No. 17-13867-KHK

* Chapter 7

Debtor. *

*

TRUSTEE'S MOTION FOR APPROVAL 

OF THE SALE OF THE DEBTOR’S INTEREST IN

REAL PROPERTY SUBJECT TO EXISTING LIENS AND RESTRICTIONS

DONALD F. KING, TRUSTEE, by counsel, files this Motion for Approval of the Sale of the 

Debtor’s Interest in Real Property pursuant to 11 U.S.C. §363 (“Sale Motion”) and, in support 

thereof, states as follows:

1. The Court has jurisdiction over this matter pursuant to 28 U.S.C. §§157 and 1334. 

This is a core proceeding pursuant to 28 U.S.C. § 157(b)(2)(A), (N) and (O).

2. Kareem Mohamad Shoura filed a voluntary chapter 7 petition on November 14, 

2017. 

3. Donald F. King was appointed the chapter 7 Trustee in this case on November 

15, 2017 (the “Trustee”).

4. Kareem Mohamad Shoura (the “Debtor” and “Mr. Shoura”) is a joint owner of a 

parcel of real estate located at 5511 Bent Maple Lane, Centerville, Virginia 20120 and is

described as follows (“Property”):

Lot 54, THE TOWNES AT FAIR LAKES GLEN, as the same 

appears duly dedicated, platted and recorded in Deed Book 

10164 at Page 529, among the land records of Fairfax County, 

Virginia.

For derivation of title see Deed recorded at Deed Book 20024, 

Page 460 among the said land records.

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5. As a result of the bankruptcy filing, the Debtor’s interest in the Property belongs to 

the chapter 7 bankruptcy estate.

6. The other co-owner, the Debtor’s father, Mohamed E. Shoura, currently resides in 

the Property.

7. The Trustee requests authority to sell the Debtor’s Property Interests pursuant to 

an offer made by his father to the Trustee to acquire the Debtor’s Property Interests.

8. Additional information regarding the proposed sale is as follows: 

A. Type of Sale: Private.

B. Buyer: Mohamed E. Shoura, Debtor’s Father1

C. Purchase Price: $10,000.00.

D. Current Value2

: $159,272

E. Place and Time of Sale: Fifteen days following entry of an order approving 

this sale. The sale will be settled and closed by the delivery of the Trustee’s 

Quit Claim Deed to Buyer. The trustee will draft the deed, which Buyer is to 

record at his own expense.

F. Realtor: None.

G. Compensation to Realtor: Not applicable.

H. Estimated Trustee's Commission: $1,750.00 per 11 U.S.C. § 326.

I. Liens: As set forth in Schedule D [Doc. No. 1 at 17-18], the Property is 

subject to liens in favor of the Virginia Housing Development. The 

Property is also subject to Affordable Dwelling Unit Covenants. The 

Debtor’s Property Interests are being sold subject to all liens of 

record and subject to the Affordable Dwelling Unit Covenants.

J. Costs of Sale: Legal fees incurred and Trustee’s commission under 11 

U.S.C. § 326.

K. Mr. Shoura’s Homestead Exemption: $0.00

 1 The Debtor consents to the proposed sale.

2 The estimated value of the Property on Zillow is $310,911. However, the Property is subject to 

Affordable Dwelling Unit Covenants that restrict its potential sales price. The Property is currently within an 

initial control period pursuant to those restrictions, which restricts its potential sale price. Fairfax County 

has advised that the control price is currently $159,272. 

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L. Tax Consequences of Sale to Bankruptcy Estate: None anticipated.

According to the Statement of Financial Affairs, the Debtor had lived at the 

Property from September 2009 to September 2016 and acquired his interest 

in the Property on August 27, 2008. As a result, the sale qualifies for the 

exclusion of gain from sale of principal residence in 26 U.S.C. § 121(a).

M. Proceeds of Sale to Bankruptcy Estate: Approximately $8,250.00 after 

payment of the Trustee commission and before legal fees following approval 

of the same by subsequent order of this Court. 

9. The Trustee, in the exercise of his business judgment, has determined that the sale 

of Mr. Shoura’s Property Interests back to his father is for full and fair consideration, and is in the 

best interest of all interested parties.

10. The Debtor’s estate will realize all of the gross proceeds of the sale which will be 

held by the Trustee pending the final distribution of the assets of this case by the Trustee.

WHEREFORE, DONALD F. KING, TRUSTEE, by counsel, moves this Court to enter an 

Order authorizing the sale of Mr. Shoura’s Property Interests in 5511 Bent Maple Lane, Centerville, 

Virginia 20120, and for such other and further relief as this Court deems just and proper.

DONALD F. KING, TRUSTEE

By Counsel

By: /s/ Bradley D. Jones

Bradley D. Jones (VSB No. 85095)

Counsel for Trustee

ODIN FELDMAN & PITTLEMAN PC

1775 Wiehle Avenue, Suite 400

Reston, Virginia 20190

Phone: 703-218-2176

Fax: 703-218-2160

Brad.Jones@ofplaw.com

#3897618v1 031070/002698

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