1604 Sunset Plaza, LLC

I. Facts and Summary of Pleadings

A. Background On December 9, 2021 (the “Petition Date”), the Debtor filed a voluntary Chapter 11 petition. Annette Rubin (“Annette”)2 is the Debtor’s president. Corporate Ownership Statement Pursuant to FRBP 1007(a)(1) and 7007.1, and LBR 1007-4 [Doc. No. 19, Case No. 2:21-bk-19157-ER]. DLJJ & Associates, LLC (“DLJJ”) is the Debtor’s manager. Statement of Financial Affairs for Non-Individuals Filing for Bankruptcy at ¶ 28 [Doc. No. 19, Case No. 2:21-bk-19157-ER]. The Stuart and Annette Rubin Family Trust Under Agreement Dated November 3, 2003 (the “Rubin Trust”) holds a 100% interest in the Debtor. Id. Annette, in her capacity as Trustee of the Rubin Trust, signed the Debtor’s Schedules and Statement of Financial Affairs. End Notes Regarding Schedules of Assets and Liabilities and Statement of Financial Affairs [Doc. No. 19, Case No. 2:21-bk-19157-ER]. On December 10, 2021, the Debtor filed a Complaint for Injunctive Relief [Adv. Doc. No. 1, Case No. 2:21-ap-01245-ER] (the “Complaint”) against PB and Lenders Foreclosure Services (“Lenders,” and together with PB, the “Defendants”). The Complaint sought preliminary and permanent injunctions…