4854-0521-9737

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

Proposed 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. ) (Joint Administration Requested)

)

DEBTORS’ 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 FEBRUARY 28, 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 FEBRUARY 28, 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 

prepetition unexpired leases of nonresidential real property (collectively, the “Leases”) 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 

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Northern District 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 brickand-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. Concurrently with 

the filing of this Motion, the Debtors have filed a motion requesting procedural consolidation 

and joint administration of these chapter 11 cases pursuant to Bankruptcy Rule 1015(b). 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 supporting this Motion and 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 (the “First Day Declaration”), filed contemporaneously herewith and 

incorporated herein by reference.

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The Debtors’ Unexpired Leases

8. As of the Petition Date, the Debtors are party to 230 leases of real property where 

the Debtors have conducted their businesses. The Debtors have evaluated all these leases to 

determine whether such leases should be rejected as part of the chapter 11 process. To that end, 

the Debtors have determined in a good-faith exercise of their business judgment to reject the 

leases listed on Exhibit 1 to the Order (the “Leases”).

9. The Debtors have determined in their business judgment that the costs of the 

Leases exceed any marginal benefits that could potentially be achieved from assignments of such 

Leases. The majority of the Leases are the Debtors’ retail locations—locations that are either are 

not profitable, are no longer operating, or are in the process of winding down operations. Prior 

to the proposed rejection of the Leases, the Debtors paid approximately $1,050,000 per month to 

lease their store locations. If rejection of the Leases as of the Petition Date is approved, the 

Debtors’ monthly store rental obligations will be reduced to approximately $850,000. Given that 

the retail locations governed by these Leases are either already shut down prepetition or are 

winding down business and will no longer be operating postpetition, there is no benefit to the 

Debtors’ estates, creditors, or parties in interest in maintaining such Leases. 

10. Before the Petition Date, the Debtors notified each affected landlord in writing of 

their unequivocal and irrevocable decision to surrender the premises and property and turn over 

keys, key codes, and security codes, if any, to each affected landlord, providing the landlords 

with opportunity to mitigate any rejection damages arising from the rejection of the applicable 

Lease. This Motion shall serve as further notice to reiterate the Debtors’ immediate surrender of 

the premises pursuant to the terms of each Lease listed in Exhibit 1, effective as of the Petition 

Date. Accordingly, to reduce postpetition administrative costs, and in the exercise of their sound 

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business judgment, the Debtors have determined that rejecting the Leases, effective as of the 

Petition Date, is in the best interests of the Debtors, their estates, and their creditors. 

11. The Debtors do not believe there is any valuable property remaining on the 

premises for the Leases sought to be rejected by this motion. The property to be abandoned 

consist of safes secured to the ground and file cabinets. The Debtors have determined that the 

property is of inconsequential value to the estate, 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 Leases Is in the Best Interests of the Debtors’ Estates.

12. 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). 

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

the Leases set forth on Exhibit 1 attached to the Order are central to the Debtors’ reorganization 

process. The Debtors have carefully reviewed the revenues generated and expenses incurred at 

the Leases and determined, in their business judgment, that the Leases are not necessary to an 

effective reorganization of the Debtors’ business. In the sound exercise of their business 

judgment, the Debtors have determined that the rejection of the Leases is in the best interests of 

their estates and creditors.

II. Retroactively Effective Relief May Be Sought Where Appropriate.

14. Section 365 of the Bankruptcy Code does not specifically address whether courts 

may order rejection to be effective retroactively. In the Fifth Circuit, the general rules is that the 

effective date of rejection is the date of entry of the court order rejecting the leases. See, e.g., In 

re Cafeteria Operators, L.P., 299 B.R. 384, 394 (Bankr. N.D. Tex. 2003) (citations omitted). 

However, courts have held that bankruptcy courts may retroactively reject executory contracts 

and unexpired leases based on a “balancing-of-the-equities” standard. See, e.g., In re Cafeteria 

Operators, L.P., 299 B.R. 384, 394 (Bankr. N.D. Tex. 2003) (explaining that “nothing precludes 

a bankruptcy court, based on the equities of the case, from approving the . . . rejection of a nonresidential real property lease retroactively to an earlier date” and granting retroactive relief for 

contract rejection where debtors were “receiving no benefit” from the lease and the contract 

counterparties “had unequivocal notice of Debtors’ intent to reject prior to the filing of the 

[motions to reject the leases]”); In re Amber’s Stores, Inc., 193 B.R. 819, 827 (Bankr. N.D. Tex. 

1996) (finding that “nothing precludes a bankruptcy court, based on the equities of the case, from 

approving” retroactive rejection and holding that a court may grant retroactive relief “where the 

equities of a case warrant, the court has the power to grant the rejection retroactively”). 

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15. Here, the balance of equities favors the rejection of the Leases effective as of the 

Petition Date. Without such relief, the Debtors would potentially incur unnecessary 

administrative expenses related to the Leases. See 11 U.S.C. § 365(d)(3). The landlords will not 

be unduly prejudiced if the rejection is deemed effective as of the Petition Date—possession of 

the premises was delivered to each respective landlord on, or prior to, the Petition Date with an 

unequivocal and irrevocable statement of surrender and abandonment of the premises to such 

landlord. Further, by this Motion, the landlords are receiving notice of the Debtors’ intention to 

reject the Leases and tender immediate possession of the applicable premises. In the event the 

Debtors are unable to turn over possession of a particular premises on or before the Petition 

Date, as anticipated, the effective date of the rejection of such Lease shall be no earlier than the 

date the Debtors turn over the premises. 

16. The Debtors will cause notice of this Motion to be served on the affected 

landlords, thereby allowing each party sufficient opportunity to respond accordingly. The 

Debtors have sought the relief requested as soon as possible in these chapter 11 cases and do not 

seek to reject the Leases effective as of the Petition Date due to any undue delay on their own 

part. Accordingly, the Debtors respectfully submit that the Court deem the Leases identified on

Exhibit 1 to the Order rejected effective as of the Petition Date.

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

17. 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 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 

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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)

18. 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

19. 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 

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 

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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

20. 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 proposed lender(s) under 

the proposed debtor in possession credit facility; (d) the lenders under the Debtors’ prepetition 

term loan agreement; (e) the counterparties to the Leases; (f) United States Attorney’s Office for 

the Northern District of Texas; (g) the Internal Revenue Service; (h) the state attorneys general 

for states in which the Debtors conduct business; and (i) 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.

Respectfully submitted this 25th day of February, 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

Proposed Counsel to the Debtors

and Debtors in Possession

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Certificate of Service

I certify that on February 25, 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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Exhibit A

Proposed Order

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4854-0521-9737

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. § (Joint Administration Requested)

§

§ 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 

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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set forth in 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 Petition 

Date.

3. The Debtors are authorized to abandon property, if any, that may be located at the 

premises and all such property is deemed abandoned effective as of the Petition Date. 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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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 

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

otherwise) that 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 # # #

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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

Proposed Counsel to the Debtors

and Debtors in Possession

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Exhibit 1

Rejected Leases

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Counterparty Debtor Counterparty Description of Lease Abandoned Personal 

Property

Rejection 

Date

AGP Assets Inc

c/o SVN/DFW Summit

3000 Race St, Ste 100

FT Worth TX 76111

(v) (817) 288-5525

(e) jeff.watson@svn.com

Cottonwood Financial 

Texas LLC

C/S#0765

3050 W Camp Wisdom Rd, Ste 

200

Grand Prairie TX 75052

Safe;

Filing cabinet(s)

February 

25, 2024

Baco Investments Inc

1225 Port Houston St

Houston TX 77029

(v) (832) 874-5577

(e) bacoinvestments@actionragsusa.com

Cottonwood Financial 

Texas LLC

C/S#0789

11400 Gulf Fwy, Ste A

Houston TX 77034

Safe;

Filing cabinet(s)

February 

25, 2024

Bellaire Bissonnet Ltd

PO Box 56783

Houston TX 77256-6783

(v) (713) 621-3079

(e) jay@jaykaplaninc.com 

Cottonwood Financial 

Texas LLC

C/S#7106

5212 Bellaire Blvd

Bellaire TX 77401

Safe;

Filing cabinet(s)

February 

25, 2024

BJL Properties LLC

PO Box 684

Liberty Lake WA 99019

(v) (509) 998-1773

(e) bjl4321@aol.com

Cottonwood Financial 

Idaho LLC

C/S#0803X

675 Kootenai Cut Off Rd, Ste D

Ponderay ID 83852

Safe;

Filing cabinet(s)

February 

25, 2024

Boekweg Real Estate Holdings LLC

c/o Reid Peevey Commercial Real Estate

2420 Wycon Drive, Suite 301

Waco TX 76712

(v) (254) 709-0456

(e) randy@reidpeevey.com

Cottonwood Financial 

Texas LLC

C/S#7229

231 Enterprise Blvd, Ste 1

Hewitt TX 76643

Safe;

Filing cabinet(s)

February 

25, 2024

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Counterparty Debtor Counterparty Description of Lease Abandoned Personal 

Property

Rejection 

Date

Buckner Jubilee Investments Group LLC

c/o The Weitzman Group

3102 Maple Ave, Ste 500

Dallas TX 75201

(v) (214) 720-3634

(e) cbrown@weitzmangroup.com

Cottonwood Financial 

Texas LLC

C/S#0723

9208 E R L Thornton Fwy, Ste 

207B

Dallas TX 75228

Safe;

Filing cabinet(s)

February 

25, 2024

CA New Plan Fixed Rate Partnership LP

c/o Brixmor Property Group

Attn: General Counsel

450 Lexington Ave, FL 13

New York NY 10017

w/COPY TO:

CA New Plan Fixed Rate Partnership LP

c/o Brixmor Property Group 

Attn: VP of Legal Svcs

1525 Faraday Ave, Ste 350

Carlsbad CA 92008

(v) (713) 660-4352

(e) angela.hernandez@brixmor.com

Cottonwood Financial 

Texas LLC

C/S#7140R

12520 Westheimer Rd, Ste E

Houston TX 77077

Safe;

Filing cabinet(s)

February 

25, 2024

Carney Texarkana LP

c/o Carney Mgt Co Inc

4500 Bowling Blvd, Ste 250

Louisville KY 40207

(v) (502) 893-3366

(e) mcarney@carneymanagement.com

Cottonwood Financial 

Texas LLC

C/S#7194

410 Walton Drive

Texarkana TX 75501

Safe;

Filing cabinet(s)

February 

25, 2024

Chanthol S Baer

2105 W Gay Ave

Gladewater TX 75647

(v) (903) 452-1091

(e) chantholsam@yahoo.com

Cottonwood Financial 

Texas LLC

C/S#7509

101 E Upshur Ave

Gladewater TX 75647

Safe;

Filing cabinet(s)

February 

25, 2024

Case 24-80035-swe11 Doc 11 Filed 02/26/24 Entered 02/26/24 01:08:29 Desc Main

Document Page 19 of 27
3

4854-0521-9737

Counterparty Debtor Counterparty Description of Lease Abandoned Personal 

Property

Rejection 

Date

Cypress Shopping Center LLC

c/o Spigel Properties Inc

70 NE Loop 410, Ste 185

San Antonio TX 78216

(v) (210) 801-8514

(e) tori@spigelproperties.com

Cottonwood Financial 

Texas LLC

C/S#7211

12220 Jones Rd, Ste E

Houston TX 77070

Safe;

Filing cabinet(s)

February 

25, 2024

Danny Foix

2620 Southwest Pkwy

Wichita Falls TX 76308

(v) (940) 733-7177

(e) dfgasman@nts-online.net

Cottonwood Financial 

Texas LLC

C/S#0718

3900 Sheppard Access Rd

Wichita Falls TX 76306

Safe;

Filing cabinet(s)

February 

25, 2024

DCTN3 Texas Portfolio No. 1 LLC

c/o N3 Real Estate

1240 N Kimball Ave

Southlake TX 76092

(v) (817) 552-6795

(e) crodriguez@n3realestate.com

Cottonwood Financial 

Texas LLC

C/S#0740

2025 S Dumas Ave, Ste 300A

Dumas TX 79029

Safe;

Filing cabinet(s)

February 

25, 2024

Deer Park Station LP

c/o The Weitzman Group

1800 Bering Dr, Ste 550

Houston TX 77057

(v) (713) 781-7111

(e) creed@weitzmangroup.com

Cottonwood Financial 

Texas LLC

C/S#7204

9001 Spencer Highway, Ste C

La Porte TX 77571

Safe;

Filing cabinet(s)

February 

25, 2024

EG Hulen/Oakmont LLC

c/o Cassco Mgt Co LLC

4200 S Hulen St, Ste 614

FT Worth TX 76109

(v) (817) 731-7396

(e) sheryl@casscoland.com

Cottonwood Financial 

Texas LLC

C/S#0751

6270 Oakmont Blvd

FT Worth TX 76132

Safe;

Filing cabinet(s)

February 

25, 2024

Case 24-80035-swe11 Doc 11 Filed 02/26/24 Entered 02/26/24 01:08:29 Desc Main

Document Page 20 of 27
4

4854-0521-9737

Counterparty Debtor Counterparty Description of Lease Abandoned Personal 

Property

Rejection 

Date

Eldridge Crossing Ltd

c/o Property Commerce Mgt Co

8811 Gaylord Dr, Ste 200

Houston TX 77024

(v) (832) 804-8508

(e) mroberts@propertycommerce.com

Cottonwood Financial 

Texas LLC

C/S#7132

12621 FM 1960 Rd W

Houston TX 77065

Safe;

Filing cabinet(s)

February 

25, 2024

EQYInvest Owner I Ltd LLP

c/o Global Realty & Mgt TX Inc

15866 Champion Forest Dr

Spring TX 77379

(v) (281) 840-5363

(e) eglackman@gfinvestments.com

Cottonwood Financial 

Texas LLC

C/S#7197

1456 Fry Rd

Houston TX 77084

Safe;

Filing cabinet(s)

February 

25, 2024

Estes Center LLC

Attn: Mark Nelon

6257 Glennox Lane

Dallas TX 75214

(v) (214) 871-9746

(e) hcigeneral@sbcglobal.net

Cottonwood Financial 

Texas LLC

C/S#0755

710 Estes Dr, Ste 104

Longview TX 75602

Safe;

Filing cabinet(s)

February 

25, 2024

Frankford Crossing Shopping

Center Dallas TX LP

c/o Glazer Properties

270 Commerce Dr

Rochester NY 14623-3506

(v) (585) 359-3000

(e) gburnham@glazer.com

Cottonwood Financial 

Texas LLC

C/S#0791

4701 Frankford Rd, Ste 213

Dallas TX 75287

Safe;

Filing cabinet(s)

February 

25, 2024

Case 24-80035-swe11 Doc 11 Filed 02/26/24 Entered 02/26/24 01:08:29 Desc Main

Document Page 21 of 27
5

4854-0521-9737

Counterparty Debtor Counterparty Description of Lease Abandoned Personal 

Property

Rejection 

Date

GMA IDAHO LLC

c/o Thornton Oliver Keller Commercial RE

250 S 5th ST, 2nd Floor

Boise ID 83702

(v) (208) 947-0809

(e) debbie@tokcommercial.com

Cottonwood Financial 

Idaho LLC

C/S#0808

7476 W State St

Boise ID 83703

Safe;

Filing cabinet(s)

February 

25, 2024

Hal R. Dixon Trust

c/o Black Realty Management Inc

801 W Riverside Avenue, Suite 510

Spokane WA 99201

(v) (509)-622-3519

(e) jlarsen@blackrealtymgt.com

Cottonwood Financial 

Idaho LLC

C/S#0811X

3134 E Mullan Ave, Ste D

Post Falls ID 83854

Safe;

Filing cabinet(s)

February 

25, 2024

Harrison Brothers Properties

c/o KM Realty Management LLC

5555 San Felipe St, Ste 510

Houston TX 77056

(v) (713) 275-2614

(e) amada@kmrealty.net

Cottonwood Financial 

Texas LLC

C/S#7201

16702 Stuebner Airline Rd, Ste C

Spring TX 77379

Safe;

Filing cabinet(s)

February 

25, 2024

I Southwest REC Ltd

Attn: Mark Cohen

5330 Alpha Rd, Ste 200

Dallas TX 75240

(v) (972) 991-9590

(e) mark@centerpointcp.com

Cottonwood Financial 

Texas LLC

C/S#0714R

1707 S Valley Mills Drive

Waco TX 76711

Safe;

Filing cabinet(s)

February 

25, 2024

Jack Brown Family III LP

PO Box 28159

Austin TX 78755

(v) (512) 413-9060

(e) paulbjbc@aol.com

Cottonwood Financial 

Texas LLC

C/S#7206

9139 Grissom Road

San Antonio TX 78251

Safe;

Filing cabinet(s)

February 

25, 2024

Case 24-80035-swe11 Doc 11 Filed 02/26/24 Entered 02/26/24 01:08:29 Desc Main

Document Page 22 of 27
6

4854-0521-9737

Counterparty Debtor Counterparty Description of Lease Abandoned Personal 

Property

Rejection 

Date

James A Kissler LLC

c/o Colliers International

755 W Front Street, Suite 300

Boise ID 83702

(v) (208) 345-6321

(e) lisa.weise@colliers.com

Cottonwood Financial 

Idaho LLC

C/S#0818

3780 W State St

Boise ID 83703

Safe;

Filing cabinet(s)

February 

25, 2024

JANPAC LLC

16800 W Cleveland Ave

New Berlin WI 53151

(v) (262) 923-7300

(e) amancuso@wisconsinvision.com

Cottonwood Financial 

Wisconsin LLC

C/S#0238

1256 N Port Washington Rd

Grafton WI 53024

Safe;

Filing cabinet(s)

February 

25, 2024

JBL Clear Lake LLC (et al)

c/o JBL Asset Mgt LLC

2028 Harrison St, Ste 202

Hollywood FL 33020

(v) (954) 323-8757

(e) george@jblmgmt.com

Parent Co: Highland Shopping Center LLC

LL (et al): JBL Clear Lake LLC (64.9%) and

JBL Clear Lake Harvest LLC (35.1%)

Cottonwood Financial 

Texas LLC

C/S#7139

1006 Bay Area Blvd

Houston TX 77058

Safe;

Filing cabinet(s)

February 

25, 2024

KRG Houston Sawyer Heights LLC

c/o Kite Realty Group LP

Attn: Legal Dept

30 S Meridian St, Ste 1100

Indianapolis IN 46204

(v) (713) 496-3877

(e) estensgaard@kiterealty.com 

Cottonwood Financial 

Texas LLC

C/S#7124

1901 Taylor St, Ste A

Houston TX 77007

Safe;

Filing cabinet(s)

February 

25, 2024

Case 24-80035-swe11 Doc 11 Filed 02/26/24 Entered 02/26/24 01:08:29 Desc Main

Document Page 23 of 27
7

4854-0521-9737

Counterparty Debtor Counterparty Description of Lease Abandoned Personal 

Property

Rejection 

Date

LBIF Holdings LLC

c/o CSM Groups

10190 Katy Freeway, Suite 350

Houston TX 77043

(v) (713) 266-8799

(e) f.yousuf@csmgroup.org

Cottonwood Financial 

Texas LLC

C/S#7111R2

9375 W FM 1097, Ste 300

Willis TX 77318

Safe;

Filing cabinet(s)

February 

25, 2024

Lee Cowan

22334 Briarcliff Drive

Spicewood TX 78669

W/COPY TO:

Lee Cowan

304 Errol Drive

Spicewood TX 78669

(v) (512) 636-3872

(e) lscowan44@gmail.com

Cottonwood Financial 

Texas LLC

C/S#7514

100 E Marshall Ave

Longview TX 75601

Safe;

Filing cabinet(s)

February 

25, 2024

LeRoy Investments LLC

c/o LTR Investments LLC

6415 County Road C

Sun Prairie WI 53590

(v) (680) 393-4468

(e) support@ltrinvest.com

Cottonwood Financial 

Wisconsin LLC

C/S#0229

1515 Madison Ave

Fort Atkinson WI 53538

Safe;

Filing cabinet(s)

February 

25, 2024

LTD West Belt Group Ltd

c/o Bluebonnet Properties

1001 S Dairy Ashford Rd, Ste 175

Houston TX 77077

(v) (713) 924-8499

(e) support@bbpmc.com

Cottonwood Financial 

Texas LLC

C/S#0769

9404 W Sam Houston Pkwy S, Ste 

D

Houston TX 77099

Safe;

Filing cabinet(s)

February 

25, 2024

Case 24-80035-swe11 Doc 11 Filed 02/26/24 Entered 02/26/24 01:08:29 Desc Main

Document Page 24 of 27
8

4854-0521-9737

Counterparty Debtor Counterparty Description of Lease Abandoned Personal 

Property

Rejection 

Date

MaxCap Investment Group LLC

c/o Escom Properties Inc

3700 74th Ave N

Brooklyn Park MN 55443

(v) (763) 424-0153

(e) blandry@escomproperties.com

Cottonwood Financial 

Wisconsin LLC

C/S#0228

146 Crossroads Dr

Plover WI 54467

Safe;

Filing cabinet(s)

February 

25, 2024

North Shopping Center LLC

c/o Republic Central Realty Inc

400 N Sam Houston Pkwy E, Ste 105

Houston TX 77060-3531

(v) (713) 410-7771

(e) ignacio@rcrcorp.com

Cottonwood Financial 

Texas LLC

C/S#7217

5675 Treaschwig Road

Spring TX 77373

Safe;

Filing cabinet(s)

February 

25, 2024

PFNE Ltd

c/o Sabre Realty Mgt Inc

16475 Dallas Pkwy, Ste 800

Addison TX 75001

(v) (972) 931-7400

(e) carla@sabrerealty.com

Cottonwood Financial 

Texas LLC

C/S#0782

3797 Forest Ln, Ste 105A

Dallas TX 75244

Safe;

Filing cabinet(s)

February 

25, 2024

Pleasant Holdings LLC

c/o Genesis Investment Properties

2439 Kuser Road

Hamilton NJ 08650

(v) 609-571-6352

(e) ceicholtz@genesis-ip.com

Cottonwood Financial 

Wisconsin LLC

C/S#0231

7115 Durand Ave, Ste D2

Sturtevant WI 53177

Safe;

Filing cabinet(s)

February 

25, 2024

Pocatello F & G LP

c/o Frazee Enterprises

2907 Shelter Island Dr, Ste 105 #276

San Diego CA 92106

(v) (619) 225-1740

(e) tmartin@frazeeproperties.com

Cottonwood Financial 

Idaho LLC

C/S#0813

705 Yellowstone Ave, Ste B

Pocatello ID 83201

Safe;

Filing cabinet(s)

February 

25, 2024

Case 24-80035-swe11 Doc 11 Filed 02/26/24 Entered 02/26/24 01:08:29 Desc Main

Document Page 25 of 27
9

4854-0521-9737

Counterparty Debtor Counterparty Description of Lease Abandoned Personal 

Property

Rejection 

Date

QEH Houston 290 LLC

c/o Wulfe Mgt Svcs Inc

1800 Post Oak Blvd, 6 BLVD PL, Ste 400

Houston TX 77056

(v) (713) 621-2229

(e) asims@wulfe.com 

Cottonwood Financial 

Texas LLC

C/S#7108

7844 W Tidwell Rd, Ste 100

Houston TX 77040

Safe;

Filing cabinet(s)

February 

25, 2024

Red River Pizza Properties LP

PO Box 353

Tioga TX 76271

(v) (940) 437-5590

(e) garriottrej@gmail.com

Cottonwood Financial 

Texas LLC

C/S#0735

960 N Beach St

FT Worth TX 76111

Safe;

Filing cabinet(s)

February 

25, 2024

RH Three LP

c/o Gregory Commercial Inc

PO Box 7084

Dallas TX 75209

(v) (214) 369-1960

(e) susan.gregcom@gmail.com

Cottonwood Financial 

Texas LLC

C/S#0731

13249 Montfort Dr

Dallas TX 75240

Safe;

Filing cabinet(s)

February 

25, 2024

San Angelo WM LLC

c/o Venture Commercial Management LLC

8235 Douglas Avenue, Suite 720

Dallas TX 75225

(v) (214) 378-1212

(e) mwright@venturedfw.com

Cottonwood Financial 

Texas LLC

C/S#7224

5150 Southland Blvd, Ste A

San Angelo TX 76904

Safe;

Filing cabinet(s)

February 

25, 2024

SBV - Fox River LLC

100 N Pond Drive, Suite F

Walled Lake MI 48390

(v) 414-390-1403

(e) alee@midamericagrp.com

Cottonwood Financial 

Wisconsin LLC

C/S#0252

1180 W Sunset Dr Ste 100

Waukesha WI 53189

Safe;

Filing cabinet(s)

February 

25, 2024

Case 24-80035-swe11 Doc 11 Filed 02/26/24 Entered 02/26/24 01:08:29 Desc Main

Document Page 26 of 27
10

4854-0521-9737

Counterparty Debtor Counterparty Description of Lease Abandoned Personal 

Property

Rejection 

Date

Spring Family Plaza LLC

1004 Kirby Drive

Houston TX 77019

(v) (713) 807-7339

(e) springfamilyplaza@gmail.com

Cottonwood Financial 

Texas LLC

C/S#7145

9466 Hammerly Blvd, Ste A

Houston TX 77080

Safe;

Filing cabinet(s)

February 

25, 2024

TCB-Bear Creek LLC

c/o Newport Capital Partners Holding LLC

353 N Clark St, Ste 3625

Chicago IL 60654

(v) (312) 724-7035

(e) alan@newportcapitalptrs.com

Cottonwood Financial 

Texas LLC

C/S#7207

4927 Highway 6

Houston TX 77084

Safe;

Filing cabinet(s)

February 

25, 2024

The Oaks of Rockport Venture Ltd

800 Wilcrest Dr, Ste 245

Houston TX 77042

(v) (832) 444-6777

(e) louis@src-properties.com

Cottonwood Financial 

Texas LLC

C/S#7133

2345 Highway 35 N

Rockport TX 78382

Safe;

Filing cabinet(s)

February 

25, 2024

TxProp 1 LLC

5196 Hwy 276 W, Ste B LB 96

Royse City TX 75189

(v) (214) 240-9041

(e) lcrosby@safaridallas.com

Cottonwood Financial 

Texas LLC

C/S#7528

305-A South Greer Blvd

Pittsburg TX 75686

Safe;

Filing cabinet(s)

February 

25, 2024

Case 24-80035-swe11 Doc 11 Filed 02/26/24 Entered 02/26/24 01:08:29 Desc Main

Document Page 27 of 27