Creditors Marwan Naboulsi and Rana Naboulsi’s Memorandum of Points and Authorities in Opposition to Receiver’s Motion for Order: (1) Approving Construction Funding Agreement with Acres Capital; (2) Authorizing Employment of Special Real Estate Counsel; (3) Approving the Form of Condominium Purchase Agreements and Authorizing the Sale of those Units Free and Clear of Liens – Filed 11/12/2021