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UNITED STATES BANKRUPTCY COURT NORTHERN DISTRICT OF NEW YORK ____________________________________________ VWP, Inc. Debtor. ____________________________________________ Case No.13-60282 Chapter 11

Debtors Response To Motion BY Creditor To Modify The Automatic Stay Pursuant to Section 362(a) The debtor through its attorney does hereby appear and allege as follows: 1. The debtor filed for relief under chapter 11 of the bankruptcy code on February 36, 2013. 2. The debtor is a company that holds two pieces of real estate that were damaged in the flood following Hurricane Irene. 3. The debtors parent corporation operated a Volkswagen parts business using the properties as part of its continuing business. 4. The Debtors principal place the two properties owned by the debtor into the FEMA Hazard Mitigation Grant Program. The program is designed to remove properties from private use for a public purpose. 5. The letter attached dated December 21, 2012 form Delaware County Chief Planner indicates that 102 Depot Street is part of the Grant program and scheduled for an appraisal to determine the amount to be paid by the government for the purchase of the property. 6. The letter dated November 27, 2012 indicates that the purchase price will be based on the fair market value pre-flood condition. 7. The debtor, therefore, is in a position to obtain a purchase price for the property which exceeds the current value of the flood damaged property without regard to the future condition of the property or the future market price.

Accordingly the debtor requests that the relief requested be denied. Dated: April 18, 2013 1

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/s/ Richard Croak __________________ Richard Croak Attorney For Debtor 314 Great Oaks Blvd. Albany, NY 12203 Tel 518-690-4410 fax 518-690-4435 rcroak@richardcroak.com