PUBLIC NOTICE OF JUDGMENT CREDITOR SALE OF ASSETS: LARRY J. WINGET LIVING TRUST

NOTICE OF SALE

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION

JPMORGAN CHASE BANK, N.A., Plaintiff/Counter-Defendant, v. LARRY J. WINGET and the LARRY J.
WINGET LIVING TRUST, Defendants/Counter-Plaintiffs.

No. 08-cv-13845
Honorable David M. Lawson

NOTICE OF SALE

I.NOTICE OF (I) SOLICITATION OF INITIAL BIDS, (II) PROPOSED SALE OF DEFENDANT’S ASSETS FREE AND CLEAR OF ALL CLAIMS AND INTERESTS, (III) AUCTION AND SALE HEARING AND (IV) RELATED RELIEF AND DATES

1. PLEASE TAKE NOTICE that on September 8, 2008, JPMorgan Chase Bank, N.A. (the “Agent”) filed a claim in United States District Court for the Eastern District of Michigan, Southern Division (the “District Court”).
2. PLEASE TAKE FURTHER NOTICE that on July 28, 2015, the District Court entered the Amended Final Judgment as to All Claims of Plaintiff/Counterdefendant JPMorgan Chase Bank, N.A. and as to Counterclaim of Defendants/Counterplaintiffs Larry J. Winget and the Larry J. Winget Living Trust in the amount of $425,113,115.59 plus attorney’s fees, costs and interest. On June 21, 2018, the District Court granted JPMorgan Chase Bank, N.A.’s Motion for Entry of Final Judgment regarding pre-judgment interest, which increased the judgment amount against Larry J. Winget and the Larry J. Winget Living Trust to $778,276,929.23. Post-judgment interest and fees continue to accrue. The Agent, as the administrative agent for the group of lenders, owed the Judgment Amount, is seeking to enforce the Final Judgment by selling at a public sale as judgment creditor those assets of the Winget Trust consisting of equity interests in certain corporations.
3. PLEASE TAKE FURTHER NOTICE that on July 27, 2023, the District Court entered an order (the “Sale Process Order”) approving the Sale Process (the “Sale Process”) attached as Exhibit 1 to the Sale Process Order, which sets forth the key dates and times related to the Sale Process. All interested bidders should carefully read the Sale Process Order and the Sale Process in their entirety.To the extent of any inconsistencies between the Sale Process, the Sale Process Order and the summary descriptions of the Sale Process in this notice, the Sale Process Order shall control in all respects.

II. CONTACT PERSONS FOR PARTIES INTERESTED IN SUBMITTING A BID

The Sale Process sets forth requirements for submitting a bid as a Qualified Bidder, and any person interested in making an offer to purchase the Assets must comply strictly with the Sale Process. Only bids from Qualified Bidders will be considered by the Agent, in accordance with the Sale Process.

Any interested bidder should contact, as soon as practical:

Angle Advisors, LLC
101 Southfield Road, 2nd Fl.
Birmingham, MI, 48009
[email protected]

III. IMPORTANT DATES AND DEADLINES

1. The following dates and deadlines may be extended by the Agent or the Court pursuant to the terms of the Sale Process and the Sale Process Order.
2. Bid Deadlines. In order to be a considered to be a Qualified Bidder, Potential Bidders must submit the Required Bid Documents in electronic format not later than 12:00 p.m. (Eastern Daylight Time) on the seventh (7th) day prior to the Public Sale (the “Qualification Deadline”).
3. Auction. The Agent shall conduct an auction (the “Auction”) with respect to the Sale Asset(s). The Auction shall be in accordance with the Sale Process and upon notice to all Qualified Bidders and Larry J. Winget. The Auction shall be conducted on April 21, 2025 at 10:00 am, at the offices of Dickinson Wright LLP, 500 Woodward Avenue, Suite 4000, Detroit, Michigan 48226-3425.
4. Confirmation Hearing. A hearing (the “Confirmation Hearing”) to confirm the Proposed Sale will be held before the Court no sooner than three (3) days following the Auction. If the Agent does not receive any bids from Qualified Bidders in accordance with the Sale Process and the Sale Process Order, the Agent will report the same to the District Court at the Confirmation Hearing.

IV. PLEASE TAKE FURTHER NOTICE that the Agent reserves the right to, in its reasonable business judgment, modify the Sale Process at any time to the extent consistent with the Sale Process Order, including, without limitation, to extend deadlines and proposed dates set forth therein, including extending the Bid Deadline, modifying the date of the Auction, and adjourning and/or rescheduling the Confirmation Hearing. This Notice is subject to the fuller terms and conditions set forth in the Sale Process Order and the Sale Process.

V.  PLEASE TAKE FURTHER NOTICE that the Sale Assets are to be sold free and clear of any and all liens, claims, encumbrances and other interests (for the avoidance of doubt, excluding existing liens, claims, interests or encumbrances existing at subsidiary entities included in the Sale Assets).

VI.  PLEASE TAKE FURTHER NOTICE that (1) a party wishing to object to the confirmation of the sale must file any such objection electronically with the District Court on the docket of JP Morgan Chase, N.A. v. Larry J. Winget and the Larry J. Winget Living Trust, Case No. 08-cv-13845 and be required to be served upon each of the following:[ (a) the Honorable David M. Lawson, United States District Court Judge; (b) counsel to the Agent; (c) counsel to Larry J. Winget and (d) counsel to The Larry J. Winget Trust not later than 4:00 p.m. Eastern Daylight Time on the date immediately prior to the Confirmation Hearing; and (2) any objections made by any party at the Confirmation Hearing shall be limited solely to objections that the Sale Process was not conducted in accordance with the Sale Process Order.

VII. PLEASE TAKE FURTHER NOTICE that only those responses or objections that are timely filed, served and received will be considered at the Confirmation Hearing. Any party failing to timely file and serve an objection prior to the Confirmation Hearing in accordance with the Sale Process Order and this Notice shall be forever barred from asserting any objection to the Sale Process or the confirmation of the sale of the Sale Assets, including with respect to the transfer of the assets free and clear of all liens, claims, encumbrances and other interests (for the avoidance of doubt, excluding existing liens, claims, interests or encumbrances existing at subsidiary entities included in the Sale Assets).

VIII. PLEASE TAKE FURTHER NOTICE that this Notice is subject to the fuller terms and conditions of the Sale Process Motion and the Sale Process Order, with such Sale Process Order controlling in the event of any conflict, and the Agent encourages parties-in-interest to review such documents in their entirety. Copies of the Sale Process Motion, the Sale Process and the Sale Process Order, as well as all related exhibits, including all other documents filed with the Court, are available on the Court’s electronic docket for cases at https://www.mied.uscourts.gov (a PACER login and password are required and can be obtained through the PACER Service Center at www.pacer.psc.uscourts.gov). In addition, copies of the Sale Process Motion may be requested from the undersigned counsel for Plaintiff Alter Domus (US) LLC.

Dated: March 24, 2025

James W. Ducayet – [email protected]
Kendra L. Stead – [email protected]
Jennifer M. Wheeler – [email protected]
Stephen Spector
SIDLEY AUSTIN LLP
Address: One South Dearborn Street Chicago, IL 60603
Tel: (312) 853-7000
Fax: (312) 853-7036
Attorneys for Plaintiff Alter Domus (US) LLC