4855-4774-5722 

Jason S. Brookner (TX Bar No. 24033684) 

Aaron M. Kaufman (TX Bar No. 24060067) 

Lydia R. Webb (TX Bar No. 24083758) 

GRAY REED 

1601 Elm Street, Suite 4600 

Dallas, TX 75201 

Telephone: (214) 954-4135 

Facsimile: (214) 953-1332 

Email: jbrookner@grayreed.com 

akaufman@grayreed.com 

lwebb@grayreed.com 

Counsel to the Debtors 

and Debtors in Possession 

 

 

IN THE UNITED STATES BANKRUPTCY COURT

FOR THE NORTHERN DISTRICT OF TEXAS

DALLAS DIVISION

 

 § 

In re: § Chapter 11 

 § 

COTTONWOOD FINANCIAL LTD., et al.,

1

 § Case No. 24-80035 (SWE) 

 § 

 Debtors. § (Jointly Administered) 

 § 

 

DEBTORS’ SECOND EMERGENCY MOTION FOR ENTRY OF AN 

ORDER (I) AUTHORIZING THE REJECTION OF CERTAIN 

LEASES, (II) AUTHORIZING THE ABANDONMENT OF 

CERTAIN PROPERTY, AND (III) GRANTING RELATED RELIEF 

EMERGENCY RELIEF HAS BEEN REQUESTED. RELIEF IS REQUESTED NOT LATER 

THAN 9:30 A.M. ON MAY 13, 2024. 

IF YOU OBJECT TO THE RELIEF REQUESTED OR YOU BELIEVE THAT 

EMERGENCY CONSIDERATION IS NOT WARRANTED, YOU MUST APPEAR AT THE 

HEARING IF ONE IS SET, OR FILE A WRITTEN RESPONSE PRIOR TO THE DATE 

THAT RELIEF IS REQUESTED IN THE PRECEDING PARAGRAPH. OTHERWISE, THE 

COURT MAY TREAT THE PLEADING AS UNOPPOSED AND GRANT THE RELIEF 

REQUESTED. 

A HEARING WILL BE CONDUCTED ON THIS MATTER ON MAY 13 2024, AT 9:30 A.M. 

IN EARLE CABELL FEDERAL BUILDING, 1100 COMMERCE STREET, 14TH FLOOR, 

COURTROOM 3, DALLAS, TEXAS, 75242. 

1

 The Debtors in these chapter 11 cases and the last four digits of each Debtors’ federal tax identification number are 

as follows: Cottonwood Financial Ltd. (1001); Cottonwood Financial Administrative Services, LLC (7228); 

Cottonwood Financial Texas, LLC (9059); Cottonwood Financial Idaho, LLC (5651); Cottonwood Financial 

Wisconsin, LLC (7075). The Debtors’ principal offices are located at 2100 W Walnut Hill Lane, Suite 300, Irving, 

TX 75038. 

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PARTICIPATION AT THE HEARING WILL ONLY BE PERMITTED BY AN AUDIO AND 

VIDEO CONNECTION. 

AUDIO COMMUNICATION WILL BE BY USE OF THE COURT’S DIAL-IN FACILITY. 

YOU MAY ACCESS THE FACILITY AT 1.650.479.3207. VIDEO COMMUNICATION WILL 

BE BY THE USE OF THE CISCO WEBEX PLATFORM. CONNECT VIA THE CISCO 

WEBEX APPLICATION OR CLICK THE LINK ON JUDGE EVERETT’S HOME PAGE. 

THE MEETING CODE IS 476 420 189. CLICK THE SETTINGS ICON IN THE UPPER 

RIGHT CORNER AND ENTER YOUR NAME UNDER THE PERSONAL INFORMATION 

SETTING. 

HEARING APPEARANCES SHOULD BE MADE ELECTRONICALLY IN ADVANCE OF 

ELECTRONIC HEARINGS. TO MAKE YOUR APPEARANCE, CLICK THE 

“ELECTRONIC APPEARANCE” LINK ON JUDGE EVERETT’S HOME PAGE. SELECT 

THE CASE NAME, COMPLETE THE REQUIRED FIELDS AND CLICK “SUBMIT” TO 

COMPLETE YOUR APPEARANCE.

The above-captioned debtors and debtors in possession (the “Debtors) respectfully state 

the following in support of this motion (this “Motion”): 

Relief Requested 

1. By this Motion, the Debtors seek entry of an order, substantially in the form 

attached hereto as Exhibit A (the “Order”): (a) authorizing the rejection of certain of their leases 

of nonresidential real property (collectively, the “Leases”), which are set forth on Exhibit 1 to the 

Order, (b) authorizing the abandonment of any de minimis equipment, furniture, and other personal 

property, and (c) granting related relief. 

Jurisdiction and Venue

2. This Court has jurisdiction over this matter pursuant to 28 U.S.C. § 1334, and this 

is a core matter pursuant to 28 U.S.C. § 157(b). 

3. Venue is proper pursuant to 28 U.S.C. §§ 1408 and 1409. 

4. The bases for the relief requested herein are sections 105(a), 365(a), and 554(a) of 

title 11 of the United States Code, 11 U.S.C. §§ 101–1532 (the “Bankruptcy Code”), rules 6006, 

and 6007 of the Federal Rules of Bankruptcy Procedure (the “Bankruptcy Rules”), and rule 9013-

1 of the Local Bankruptcy Rules of the United States Bankruptcy Court for the Northern District 

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of Texas (the “Local Rules”), and paragraph 34 of the Procedures for Complex Cases in the 

Northern District of Texas (the “Complex Case Procedures”). 

Background 

5. The Debtors operate one of the largest privately held retail consumer finance 

companies in the United States. Through its Cash Store® brand, the Debtors offer their customers 

an array of financial products and consumer-lending services, including single payment cash 

advances, installment cash advances and title loans. The Debtors utilize an innovative mix of 

financial technology (fintech) through its online customer portal and brick-and-mortar financial 

products and services through its 181 retail locations across Texas, Idaho and Wisconsin. 

6. On February 25, 2024 (the “Petition Date”), each Debtor filed a voluntary petition 

for relief under chapter 11 of the Bankruptcy Code. The Debtors are operating as debtors in 

possession pursuant to sections 1107(a) and 1108 of the Bankruptcy Code. No request for the 

appointment of a trustee or examiner has been made in these chapter 11 cases, and no committees 

have been appointed. 

7. A detailed description of the Debtors and their businesses, and the facts and 

circumstances regarding the Debtors’ chapter 11 cases, are set forth in the Declaration of Karen 

Nicolaou, Chief Restructuring Officer, in Support of Chapter 11 Petitions and First Day Motions

[Docket No. 19] (the “First Day Declaration”). 

The Debtors’ Unexpired Leases 

8. Prior to the Petition Date, the Debtors were party to 230 leases of real property 

where the Debtors conducted their business. As part of these bankruptcy cases, the Debtors 

rejected 44 leases effective as of the Petition Date. See Order (I) Authorizing the Rejection of 

Certain Leases, (II) Authorizing the Abandonment of Certain Property, and (III) Granting Related 

Relief [Docket No. 109]. 

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9. On March 22, 2024, the Court entered its Order (A) Approving Bidding Procedures 

and Certain Bid Protections, (B) Scheduling a Bid Deadline, Auction, and Sale Hearing and 

Approving the Form and Manner of Notice Thereof, and (C) Approving Cure Procedures and the 

Form and Manner of Notice Thereof [Docket No. 151] (the “Bidding Procedures Order”),2

approving certain Bidding Procedures. 

10. Pursuant to the terms of the Bidding Procedures Order, the Debtors selected Axcess 

Financial Holdings, LLC as the Successful Bidder (as defined in the Bidding Procedures Order) 

for the Debtors’ assets. See Notice of Designation of Successful Bidder [Docket No. 246] (the 

“Notice of Successful Bidder”). The Successful Bidder’s asset purchase agreement, attached to the 

Notice of Successful Bidder as Exhibit A (the “APA”) sets forth the leases to be excluded by the 

Successful Bidder upon closing and consummation of the sale (the “Excluded Leases”).

11. The Debtors now seek to reject the 29 Excluded Leases, which are set forth on 

Exhibit 1 attached to the Order. To the extent the Debtors have not yet vacated the Excluded 

Leases,3 the Debtors intend to vacate the Excluded Leases by May 31, 2024. This Motion shall 

serve as notice regarding the Debtors’ intent to surrender the premises pursuant to the terms of 

each lease listed in Exhibit 1, effective as of the date set forth therein. 

12. Because these leases are listed as Excluded Leases by the Successful Bidder, the 

Debtors have determined that rejecting the Excluded Leases is in the best interests of the Debtors, 

their estates, and their creditors. Rejecting the Excluded Leases is a sound exercise of the Debtors’ 

sound business judgment, as it will reduce postpetition administrative costs. 

2

 Capitalized terms not defined herein have the meaning as defined in the Bidding Procedures Order. 

3

 The Debtors previously vacated and tendered possession of the premises governed by the lease with 1901 Gateway 

Holdings, LLC (the “Gateway Lease”) on April 30, 2024. As a result, the Debtors seek to reject the Gateway Lease 

as of April 30, 2024. 

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13. Once vacated, the only remaining property on the premises of the Excluded Leases 

will consist of safes secured to the ground and file cabinets.4

 The Debtors have determined that 

this property is of inconsequential value to the estates, or that the cost of removing and storing 

such property outweighed any potential benefit of retaining such property. Accordingly, to reduce 

postpetition administrative costs and, in the exercise of their sound business judgment, the Debtors 

believe that the abandonment of the property that may be located at each of the premises, if any, is 

appropriate and in the best interests of the Debtors, their estates, and their creditors.

Basis for Requested Relief 

I. The Rejection of Excluded Leases Is in the Best Interests of the Debtors’ Estates. 

14. Section 365(a) of the Bankruptcy Code provides that a debtor in possession “may 

assume or reject any executory contract or unexpired lease of the debtor” subject to the court’s 

approval. 11 U.S.C. § 365(a). Courts generally authorize debtors to assume or reject executory 

contracts and unexpired leases where the debtors appropriately exercise their “business judgment.” 

See, e.g., In re Senior Care Centers, LLC, 607 B.R. 580, 587 (Bankr. N.D. Tex. 2019) (“A court 

evaluates whether a lease should be assumed or rejected employing the business judgment 

standard.”) (citation omitted); In re TM Vill., Ltd., No. 18-32770, 2019 WL 1004571, at *10 (Bankr. 

N.D. Tex. Feb. 28, 2019) (“A debtor must satisfy his fiduciary duty to . . . creditors and equity 

holders, by articulating some business justification for using, selling, or leasing the property 

outside the ordinary course of business.”) (internal quotations and alternations omitted) (citation 

omitted). 

4

 Under the APA, the Buyer is buying the Purchased Assets listed in Section 2.1 of the APA, which Purchased Assets 

includes (but is not limited to) all Cash and Cash Equivalents and Accounts Receivable (as defined in the APA) 

currently located at, or associated with, the Debtors’ sites subject to Excluded Leases. 

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15. The Debtors have determined, in their sound business judgment, that rejection of 

the Excluded Leases set forth on Exhibit 1 attached to the Order is helpful to the Debtors’ 

reorganization process, as such rejection will facilitate the sale process with the Successful Bidder. 

The Successful Bidder has excluded these leases from leases to be assigned to them by and through 

the sale process. Therefore, in the sound exercise of their business judgment, the Debtors have 

determined that the rejection of the Excluded Leases is in the best interests of their estates and 

creditors. 

16. The landlords will not be unduly prejudiced if the rejection is deemed effective as 

of the date set forth on Exhibit 1 to the Order. Possession of the premises was or will be delivered 

to each respective landlord on, or prior to such date with an unequivocal and irrevocable statement 

of surrender and abandonment of the premises to such landlord and an unequivocal statement of 

intent not to renew such Excluded Lease. Further, by this Motion, the landlords are receiving 

notice of the Debtors’ intention to reject the Excluded Leases and tender possession of the 

applicable premises. In the event the Debtors are unable to turn over possession of a particular 

premises on or before the anticipated date, the effective date of the rejection of such Excluded 

Lease shall be no earlier than the date the Debtors turn over the premises. 

17. The Debtors will cause notice of this Motion to be served on the affected landlords, 

thereby allowing each landlord sufficient opportunity to respond accordingly. The Debtors have 

sought the relief requested as soon as possible following entry into the APA and do not seek to 

reject the Excluded Leases due to any undue delay on their own part. Accordingly, the Debtors 

respectfully submit that the Court deem the Excluded Leases identified on Exhibit 1 to the Order 

rejected effective as of the date set forth therein. 

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II. Abandonment of Personal Property Is in the Best Interests of the Debtors’ Estates. 

18. Bankruptcy Code section 554(a) provides that “[a]fter notice and a hearing, the 

trustee may abandon any property of the estate that is burdensome to the estate or that is of 

inconsequential value and benefit to the estate.” 11 U.S.C. § 554(a). Any property to be 

abandoned at the premises of certain Excluded Leases would be of inconsequential value or 

burdensome to the Debtors’ estates, and the cost of retrieving, marketing, and reselling such 

abandoned property would outweigh any recovery the Debtors could attain for such property. 

Accordingly, the abandonment of such property is in the best interests of the Debtors, their estates, 

and their creditors, and parties in interest will have sufficient notice of such abandonment. 

Bankruptcy Rules 6006(c) and 6007(a) 

19. The Debtors request that the Court enter an order providing that notice of the relief 

requested herein satisfies Bankruptcy Rules 6006(c) and 6007(a). 

Reservation of Rights 

20. Nothing contained herein or any actions taken pursuant to such relief requested is 

intended or shall be construed as: (a) an admission as to the amount of, basis for, or validity of 

any claim against a Debtor entity under the Bankruptcy Code or other applicable nonbankruptcy 

law; (b) a waiver of the Debtors’ or any other party in interest’s right to dispute any claim on any 

grounds; (c) a promise or requirement to pay any claim; (d) an implication or admission that any 

particular claim is of a type specified or defined in this Motion or any order granting the relief 

requested by this Motion or a finding that any particular claim is an administrative expense claim 

or other priority claim; (e) a request or authorization to assume, adopt, or reject any agreement, 

contract, or lease pursuant to section 365 of the Bankruptcy Code, other than the relief requested 

in the Motion; (f) an admission as to the validity, priority, enforceability, or perfection of any lien 

on, security interest in, or other encumbrance on property of the Debtors’ estates; (g) a waiver or 

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4855-4774-5722 

limitation of the Debtors’, or any other party in interest’s, rights under the Bankruptcy Code or any 

other applicable law; or (h) a concession by the Debtors that any liens (contractual, common law, 

statutory, or otherwise) that may be satisfied pursuant to the relief requested in this motion are 

valid, and the rights of all parties in interest are expressly reserved to contest the extent, validity, 

or perfection or seek avoidance of all such liens. If the Court grants the requested relief, any 

payment made pursuant to the Court’s order is not intended and should not be construed as an 

admission as to the validity of any particular claim or a waiver of the Debtors’ or any other party 

in interest’s rights to subsequently dispute such claim. 

Notice 

21. The Debtors will provide notice of this motion to the following parties or their 

counsel: (a) the U.S. Trustee for the Northern District of Texas; (b) the holders of the 30 largest 

unsecured claims against the Debtors (on a consolidated basis); (c) the DIP Lender; (d) the lenders 

under the Debtors’ prepetition term loan agreement; (e) the counterparties to the Excluded Leases; 

(f) the Successful Bidder; (g) United States Attorney’s Office for the Northern District of Texas; 

(h) the Internal Revenue Service; (i) the state attorneys general for states in which the Debtors 

conduct business; and (j) any party that has requested notice pursuant to Bankruptcy Rule 2002. 

In light of the nature of the relief requested, the Debtors submit that no other or further notice is 

needed. 

WHEREFORE, the Debtors respectfully request that the Court enter an order, substantially 

in the form attached hereto as Exhibit A, granting the relief requested herein and such other relief 

as the Court deems appropriate under the circumstances. 

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4855-4774-5722 

Respectfully submitted this 6th day of May, 2024. 

GRAY REED 

 

By: /s/ Lydia R. Webb 

Jason S. Brookner (TX Bar No. 24033684) 

Aaron M. Kaufman (TX Bar No. 24060067) 

Lydia R. Webb (TX Bar No. 24083758) 

1601 Elm Street, Suite 4600 

Dallas, Texas 75201

Telephone: (214) 954-4135 

Facsimile: (214) 953-1332 

Email: jbrookner@grayreed.com 

akaufman@grayreed.com 

lwebb@grayreed.com 

Counsel to the Debtors 

and Debtors in Possession

Certificate of Service 

 I certify that on May 6, 2024, I caused a copy of the foregoing document to be served by 

the Electronic Case Filing System for the United States Bankruptcy Court for the Northern District 

of Texas. 

/s/ Lydia R. Webb 

Lydia R. Webb 

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4855-4774-5722 

Exhibit A 

Proposed Order

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4855-4774-5722 

 

IN THE UNITED STATES BANKRUPTCY COURT 

FOR THE NORTHERN DISTRICT OF TEXAS 

DALLAS DIVISION

 

 § 

In re: § Chapter 11 

 § 

COTTONWOOD FINANCIAL LTD., et al.,

1

 § Case No. 24-80035 (SWE) 

 § 

 Debtors. § (Jointly Administered) 

 § 

 § Re: Docket No. __ 

ORDER (I) AUTHORIZING THE REJECTION OF 

CERTAIN LEASES, (II) AUTHORIZING THE ABANDONMENT 

OF CERTAIN PROPERTY, AND (III) GRANTING RELATED RELIEF 

Upon the motion (the “Motion”),2 of the above-captioned debtors and debtors in possession 

(the “Debtors”) for entry of an order (this “Order”), (a) authorizing the rejection of certain leases 

set forth on Exhibit 1 hereto, (b) authorizing the abandonment of any de minimis equipment, 

furniture, and other personal property, and (c) granting related relief, all as more fully set forth in 

1

 The Debtors in these chapter 11 cases and the last four digits of each Debtors’ federal tax identification number are 

as follows: Cottonwood Financial Ltd. (1001); Cottonwood Financial Administrative Services, LLC (7228); 

Cottonwood Financial Texas, LLC (9059); Cottonwood Financial Idaho, LLC (5651); Cottonwood Financial 

Wisconsin, LLC (7075). The Debtors’ principal offices are located at 2100 W Walnut Hill Lane, Suite 300, Irving, 

TX 75038. 

2

 Capitalized terms used but not otherwise defined herein shall have the meanings ascribed to them in the Motion. 

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2 

4855-4774-5722 

the Motion; and upon the First Day Declaration; and this Court having jurisdiction over this matter 

pursuant to 28 U.S.C. § 1334; and this Court having found that this is a core proceeding pursuant 

to 28 U.S.C. § 157(b)(2); and this Court having found that it may enter a final order consistent 

with Article III of the United States Constitution; and this Court having found that venue of this 

proceeding and the Motion in this district is proper pursuant to 28 U.S.C. §§ 1408 and 1409; and 

this Court having found that the Debtors’ notice of the Motion and opportunity for a hearing on 

the Motion were appropriate under the circumstances and no other notice need be provided; and 

this Court having reviewed the Motion, and all objections, if any, to the Motion having been 

withdrawn, resolved, or overruled; and the Court having determined that the legal and factual bases 

set forth in the Motion and the record of the hearing on such motion establish just cause for the 

relief granted herein; and this Court having found that the relief requested in the Motion is in the 

best interests of the Debtors’ estates, their creditors, and other parties in interest; and upon all of 

the proceedings had before this Court; and after due deliberation and sufficient cause appearing 

therefore, IT IS HEREBY ORDERED THAT: 

1. The Motion is granted as set forth herein. 

2. The leases set forth on Exhibit 1 hereto are rejected effective as of the date set forth 

therein. 

3. The Debtors are authorized to abandon property, if any, that does not constitute 

Purchased Assets under the APA (as defined in the Motion), that may be located at the premises 

and all such property is deemed abandoned effective as of the date set forth on Exhibit 1. The 

applicable counterparty to each lease may effectuate its rights and remedies with respect to such 

property. The automatic stay, to the extent applicable, is modified to allow for such utilization or 

disposition. 

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4855-4774-5722 

4. Approval of this Order will not prevent the Debtors from seeking to assume or 

reject an executory contract or unexpired lease by separate motion or pursuant to a chapter 11 plan. 

5. The Debtors are authorized to take all actions necessary to effectuate the relief 

granted pursuant to this Order in accordance with the Motion. 

6. All rights and defenses of the Debtors are preserved, including all rights and 

defenses of the Debtors with respect to a claim for damages arising as a result of an executory 

contract or lease rejection, including any right to assert an offset, recoupment, counterclaim, or 

deduction. In addition, nothing in this Order or the Motion shall limit the Debtors’ ability to 

subsequently assert that any particular executory contract or lease is terminated and is no longer 

an executory contract or unexpired lease, respectively. 

7. Notwithstanding the relief granted in this Order pursuant to the Motion and any 

actions taken pursuant to such relief, nothing in this Order shall be deemed: (a) an admission as 

to the amount of, basis for, or validity of any claim against a Debtor entity under the Bankruptcy 

Code or other applicable nonbankruptcy law; (b) a waiver of the Debtors’ or any other party in 

interest’s right to dispute any claim on any grounds; (c) a promise or requirement to pay any claim; 

(d) an implication or admission that any particular claim is of a type specified or defined in this 

Order or the Motion or a finding that any particular claim is an administrative expense claim or 

other priority claim; (e) a request or authorization to assume, adopt, or reject any prepetition 

agreement, contract, or lease pursuant to section 365 of the Bankruptcy Code; (f) an admission as 

to the validity, priority, enforceability, or perfection of any lien on, security interest in, or other 

encumbrance on property of the Debtors’ estates; (g) a waiver or limitation of the Debtors’ or any 

other party in interest’s rights under the Bankruptcy Code or any other applicable law; or (h) a 

concession by the Debtors that any liens (contractual, common law, statutory, or otherwise) that 

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4 

4855-4774-5722 

may be satisfied pursuant to the Motion are valid, and the rights of all parties in interest are 

expressly reserved to contest the extent, validity, or perfection or seek avoidance of all such liens. 

8. The contents of the Motion satisfy the requirements of Bankruptcy Rule 6003(b). 

9. Notice of the Motion as provided therein shall be deemed good and sufficient notice 

of such Motion and the requirements of Bankruptcy Rules 6006(c) and 6007(a), and the Local 

Rules are satisfied by such notice. 

10. The requirements of Bankruptcy Rule 6006(f) have been satisfied. 

11. The terms and conditions of this Order are immediately effective and enforceable 

upon its entry. 

12. The Debtors are authorized to take all reasonable actions necessary to effectuate 

the relief granted in this Order in accordance with the Motion. 

13. This Court retains jurisdiction with respect to all matters arising from or related to 

the implementation, interpretation, and enforcement of this Order. 

# # # END OF ORDER # # # 

Submitted by: 

Jason S. Brookner (TX Bar No. 24033684) 

Aaron M. Kaufman (TX Bar No. 24060067) 

Lydia R. Webb (TX Bar No. 24083758) 

GRAY REED 

1601 Elm Street, Suite 4600 

Dallas, TX 75201 

Telephone: (214) 954-4135 

Facsimile: (214) 953-1332 

Email: jbrookner@grayreed.com

akaufman@grayreed.com 

lwebb@grayreed.com 

Counsel to the Debtors 

and Debtors in Possession

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4855-4774-5722 

Exhibit 1 

Rejected Leases 

 

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4855-4774-5722 

Debtor Counterparty Description of Lease Abandoned Personal Property 

Cottonwood Financial Texas, LLC 

Store 7131, located at 

2600 S. Kirkwood Rd., Ste. 300, 

Houston, TX 

Safe; filing cabinet(s) 

Cottonwood Financial Texas, LLC 

Store 729, located at 

5949 Broadway Blvd., Ste. 140, 

Garland, TX 

Safe; filing cabinet(s) 

Cottonwood Financial Texas, LLC 

Store 710, located at 

301 E US Highway 82 Ste D-1, 

Sherman, TX 

Safe; filing cabinet(s) 

Cottonwood Financial Wisconsin, 

LLC 

Store 233, located at 

5630 Washington Ave Ste 9, 

Racine, WI 

Safe; filing cabinet(s) 

Cottonwood Financial Texas, LLC 

Store 783, located at 

6921 Lakeview Haven Drive Ste. 100, 

Houston, TX 

Safe; filing cabinet(s) 

Cottonwood Financial Texas, LLC 

Store 709, located at 

1922 E Southeast Loop 323 Ste 1912, 

Tyler, TX 

Safe; filing cabinet(s) 

Cottonwood Financial Texas, LLC 

Store 727, located at 

1517 Interstate 35 N. Ste. 110, 

Waco, TX 

Safe; filing cabinet(s) 

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4855-4774-5722 

Debtor Counterparty Description of Lease Abandoned Personal Property 

Cottonwood Financial Idaho, LLC 

Store 806, located at 

589 E. 17th St., 

Idaho Falls, ID 

Safe; filing cabinet(s) 

Cottonwood Financial Texas, LLC 

Store 715, located at 

811 Hillcrest Dr, 

Vernon, TX 

Safe; filing cabinet(s) 

Cottonwood Financial Texas, LLC 

Store 7103, located at 

2050 W University Dr Ste 130, 

McKinney, TX 

Safe; filing cabinet(s) 

Cottonwood Financial Texas, LLC 

Store 7231, located at 

7600 N. MacArthur Blvd., Ste. 150, 

Irving, TX 

Safe; filing cabinet(s) 

Cottonwood Financial Idaho, LLC 

Store 812, located at 

1850 Caldwell Blvd, Ste 150, 

Nampa, ID 

Safe; filing cabinet(s) 

Cottonwood Financial Wisconsin, 

LLC 

Store 223, located at 

421 Main St W, 

Ashland, WI 

Safe; filing cabinet(s) 

Cottonwood Financial Wisconsin, 

LLC 

Store 203, located at 

1111 N. Sherman Ave., 

Madison, WI 

Safe; filing cabinet(s) 

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4855-4774-5722 

Debtor Counterparty Description of Lease Abandoned Personal Property 

Cottonwood Financial Wisconsin, 

LLC 

Store 219, located at 

135 S. Water St., 

Platteville, WI 

Safe; filing cabinet(s) 

Cottonwood Financial Wisconsin, 

LLC 

Store 221, located at 

37885 Selch Rd Ste 101, 

Prairie du Chien, WI 

Safe; filing cabinet(s) 

Cottonwood Financial Wisconsin, 

LLC 

Store 234, located at 

1907 Market Way, Ste. G, 

Watertown, WI 

Safe; filing cabinet(s) 

Cottonwood Financial Wisconsin, 

LLC 

Store 237, located at 

530 Walton Dr., 

Plymouth, WI 

Safe; filing cabinet(s) 

Cottonwood Financial Wisconsin, 

LLC 

Store 206, located at 

1931 N Shawano St Ste 250, 

New London, WI 

Safe; filing cabinet(s) 

Cottonwood Financial Texas, LLC 

Store 728, located at 

1301 W Glade Rd Ste 144, 

Euless, TX 

Safe; filing cabinet(s) 

Cottonwood Financial Texas, LLC 

Store 750, located at 

5345 N Garland Ave Ste 380, 

Garland, TX 

Safe; filing cabinet(s) 

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4855-4774-5722 

Debtor Counterparty Description of Lease Abandoned Personal Property 

Cottonwood Financial Texas, LLC 

Store 7105, located at 

721 Hebron Pkway, Ste 110, 

Lewisville, TX 

Safe; filing cabinet(s) 

Cottonwood Financial Texas, LLC 

Store 721, located at 

4045 S Great 

Southwest Pkwy Ste 117, 

Grand Prairie, TX 

Safe; filing cabinet(s) 

Cottonwood Financial Texas, LLC 

Store 7185, located at 

27676-C Tomball Parkway, 

Tomball, TX 

Safe; filing cabinet(s) 

Cottonwood Financial Texas, LLC 

Store 7511, located at 

2207 Hwy 79 S, 

Henderson, TX 

Safe; filing cabinet(s) 

Cottonwood Financial Texas, LLC 

Store 7143, located at 

6387 Camp Bowie Blvd Ste A., 

Fort Worth, TX 

Safe; filing cabinet(s) 

Cottonwood Financial Texas, LLC Store 7133, located in Rockport, TX Safe; filing cabinet(s) Cottonwood Financial Texas, LLC 

Store 7198, located at 

2005 S Washington Street, 

Kaufman, TX 

Safe; filing cabinet(s) 

Case 24-80035-swe11 Doc 258 Filed 05/06/24 Entered 05/06/24 09:16:32 De

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5 

4855-4774-5722 

Debtor Counterparty Description of Lease Abandoned Personal Property 

Cottonwood Financial 

Administrative Services, LLC 

Lease Agreement, dated as of April 30, 2021, by and between 1901 Gateway Holdings, LLC and Cottonwood Financial Administrative Services, LLC, as amended by that certain Notice of Lease Renewal, dated January 5, 2023, and that certain Notice of Lease Renewal, dated October 4, 2023. 

None 

Case 24-80035-swe11 Doc 258 Filed 05/06/24 Entered 05/06/24 09:16:32 De

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