IMO Estate of Reginald E. Watson, Sr.

COURT OF CHANCERY
OF THE
STATE OF DELAWARE
DANIELLE GIBBS LEONARD L. WILLIAMS JUSTICE CENTER
MAGISTRATE IN CHANCERY 500 NORTH KING STREET, SUITE 11400
WILMINGTON, DE 19801-3734

Date Submitted: July 16, 2025
Date Decided: October 28, 2025

BY FILE & SERVEXPRESS VIA U.S. MAIL AND EMAIL
Timothy Ferry, Esquire Myesha Moorefield
Ferry Joseph, P.A. 2307 N. Market Street
1521 Concord Pike, Suite 202 Wilmington, DE 19802
Wilmington, DE 19803 mariebosslady6@icloud.com

Re: IMO Estate of Reginald E. Watson, Sr.,
C.A. No. 2025-0063-DG

Dear Mr. Ferry and Ms. Moorefield:
This Report contains my conclusions regarding Petitioner’s

Application for Rule to Show Cause filed under Title 12, Section 2702 of the

Delaware Code. Petitioner asks the Court to compel Ms. Moorefield—the

representative of the Estate of Reginald E. Watson, Sr. (the “Estate”)—to sell

the property known as 2601 Baxter Avenue, in Wilmington, Delaware (the

“Property”) to satisfy a debt of the Estate.

The Rule issued on January 31, 2025. I held an evidentiary hearing on

July 16.1 After considering the testimony and exhibits presented at the

1
I held a status conference on April 2, 2025, and a show cause hearing was
scheduled for May 19. Docket Items (“D.I.”) 25; 26. I rescheduled the hearing to
C.A. No. 2025-0063-DG
October 28, 2025
Page 2 of 18

hearing, as well as items on the Estate’s docket in the Register of Wills and

the docket in this civil action, I conclude that Respondent has not

demonstrated sufficient cause for the Court to deny Petitioner’s request.

Accordingly, I recommend that Respondent, as Estate representative, be

required to sell the Property.

I state the facts as I find them after the hearing, and my conclusions,

below.

The Parties

Petitioner GitSit Solutions, LLC (“GitSit”) is “a holder and servicer of

home mortgages.”2 Petitioner is “the current and sole owner” of a note and

mortgage executed by Reginald E. Watson, Sr. (“Decedent”) in 2011.3

Petitioner acquired the note and mortgage on January 24, 2024.4

June 2, at Respondent’s request, due to personal difficulties, D.I. 27; 30, and
ultimately to July 16, upon receipt of late-filed exhibits from Respondent. D.I. 34;
35. One week before the July 16 hearing, Respondent asked the Court to conduct
an investigation into “serious irregularities” and “potential fraud” related to the
transactions at issue in this matter. See Summary Assignments and Chains Fraud,
D.I. 39 at 2. The Court does not conduct investigations.
2
Transcript of July 16 Evidentiary Hearing (“Tr.”), D.I. 41 at 58:21–22.
3
Id. at 59:13–14, 60:7–9. Petitioner is the payee under the terms of the note and the
holder of the mortgage. Id. at 59:17–20.
4
See IMO Watson Sr., Reginald E. (DOD 02/08/2021), ROW 186822 PJT (Del.
Ch.), D.I. 26 (cited as the “Mortgage”) at 27. The Court has taken judicial notice of
the Mortgage and assignment documents. See D.R.E. 202(d)(1)(C).
C.A. No. 2025-0063-DG
October 28, 2025
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Respondent Myesha Moorefield is Decedent’s granddaughter and the

successor personal representative of his Estate.5 Respondent lived in the

Property when she was a child,6 and she remains a resident of Wilmington,

Delaware.7

Decedent and His Will

Decedent executed a Will in 2010.8 The Will named Decedent’s son,

Reginald E. Watson, Jr., as executor.9 Decedent died on February 8, 2021.10

Decedent’s son did not open an estate.

For purposes of this Report, Decedent’s Will did not “surface” until

April 30, 2024.11 The record does not reflect the location of the Will between

5
Tr. at 11:2–12; 56:7–10.
6
See id. at 106:8–9 (“This is my childhood home.”); 109:9 (“I grew up in the
house.”).
7
Id. at 9:15–18.
8
See Petitioner’s Exhibit (“PX”) 4 at 9 ¶ A (Last Will and Testament of Reginald
E. Watson).
9
Id. at 15. Decedent’s son renounced his power of administration effective June 5,
2024. See Watson, ROW 186822 PJT, D.I. 11. Respondent refers to Decedent’s
son as her uncle. Tr. at 14:4–6.
10
Pet. for an Order for a R. to Show Cause (“Petition”), D.I. 1 ¶ 1; Tr. at 18:1–12.
11
The Will was filed more than one month after Petitioner’s then-counsel opened
the Estate. See Watson, ROW 186822 PJT, D.I. 7. The reason for the delay does
not appear in the record.
C.A. No. 2025-0063-DG
October 28, 2025
Page 4 of 18

2021 and 2024. Respondent testified that she was not aware of the Will before

2024.12

The Reverse Mortgage

On March 9, 2011, nearly a decade before his death, Decedent entered

into a fixed-rate home equity conversion loan, more commonly known as a

reverse mortgage (“Mortgage”).13 In short, Decedent obtained a loan of up to

$288,000, secured by the Property.14 The Mortgage provided that, upon

Decedent’s death, the lender would be entitled to sell the Property in

satisfaction of the loan.15 The Mortgage is recorded in the land records of

New Castle County.16

12
Tr. at 114:8–10.
13
Mortgage at 6.
14
See id. at 7.
15
See id. at 12 ¶ 10 (“Lender may enforce the debt only through sale of the
Property.”).
16
See id. at 6; see also Tr. at 60:22–61:2 (relevant mortgage documents were
recorded in New Castle County).
C.A. No. 2025-0063-DG
October 28, 2025
Page 5 of 18

Reverse mortgages are federally insured.17 Thus, Decedent’s loan was

originally evidenced by two mortgages -- one with the lending bank and one

with the Department of Housing and Urban Development (“HUD”).18

The Assignments

The Mortgage was assigned three times after 2011.19 The assignments

reflect that they have been recorded.20 The final assignment was made by

HUD, “by its attorney-in-fact GitSit Solutions, LLC” (the “POA”), to

Petitioner.21

Petitioner’s First Attempt to Recover

After acquiring the debt in January 2024, Petitioner retained counsel in

Delaware to open an estate for Decedent and pursue a process of “special

17
Tr. at 68:6–7.
18
Id. at 68:6–68:18.
19
Mortgage at 23–28 (reflecting assignments in 2012, 2018 and 2024). The
documents and assignments, collectively, have not been consecutively numbered.
The numbers stated here are the Court’s count of the pages.
20
Id. Petitioner’s witness testified that the assignment to Petitioner is recorded. See
Tr. at 60:10–20.
21
Mortgage at 27. The documents also reflect that the POA was recorded. See id.
C.A. No. 2025-0063-DG
October 28, 2025
Page 6 of 18

administration.”22 In accordance with the terms of the Mortgage, Petitioner

intended to sell the Property to satisfy the debt.23

Petitioner’s then-counsel, Charles Knothe, opened Decedent’s Estate

on March 25 and became its first representative.24 Mr. Knothe filed an

inventory representing that the Estate had one asset—the Property, valued at

$290,000—and that Decedent had one next of kin—his son.25

Mr. Knothe negotiated a contract to sell the Property at a price below

the amount of the debt, which Petitioner accepted.26 Unfortunately, Mr.

Knothe died on September 16, and the sale did not occur.27

22
See Tr. at 62:18–63:6. See also 12 Del. C. § 1505(d), (e) (providing the Register
of Wills discretion to grant letters testamentary to any interested person who seeks
appointment, if no petition filed within 60 days of death). At the hearing,
Petitioner’s witness explained the options of special administration and foreclosure,
and why Petitioner prefers the former option. Tr. at 85:14–86:3.
23
See Tr. at 62:23–24.
24
Petition, D.I. 1 ¶¶ 2; 6–7. Mr. Knothe opened the Estate intestate and filed the
Will later. Compare Watson, ROW 186822 PJT, D.I. 1–5 (original petition with
supplemental items) with Watson, ROW 186822 PJT, D.I. 7 (Decedent’s Will).
25
Watson, ROW 186822 PJT, D.I. 3. See 12 Del. C. § 1905(c) (administrator must
represent by affidavit that all known goods and real estate have been listed). It is
not clear how counsel determined the value of the Property.
26
Tr. at 63:1–5.
27
Id. at 63:4–6.
C.A. No. 2025-0063-DG
October 28, 2025
Page 7 of 18

Petitioner Regroups

Petitioner retained new counsel shortly after Mr. Knothe’s death.28

Petitioner then contacted Respondent and other members of Decedent’s

family and “offered them the ability to renounce their right to take action so

the property could be sold, in lieu of [Petitioner] having [Petitioner] having to

go through foreclosure and personally name them in that foreclosure suit.”29

Several family members renounced their interest in the Property, but

Respondent did not.30 Instead, Respondent petitioned to become successor

personal representative of the Estate.31 Respondent was appointed on

28
Id. at 63:23–64:9. See Watson, ROW 186822 PJT, D.I. 18 (Counsel’s Petition for
Letters of Administration filed October 30, 2024).
29
Tr. at 65:22–66:12.
30
Id. at 66:13–17. Mr. Williams testified that Respondent’s mother also declined.
Id. at 66:16–17.
31
Id. at 64:10–17. Ms. Moorefield had apparently been in touch with the Register
of Wills in April of 2024 to discuss opening an estate. See PX 6. Respondent did
not actually file a petition to do so, however, until December of that year. See
Watson, ROW 186822 PJT, D.I. 22. Respondent sought appointment only after
receiving notice that Petitioner’s counsel had petitioned for appointment. See Tr. at
40:8–19.
C.A. No. 2025-0063-DG
October 28, 2025
Page 8 of 18

December 5, 2024.32 In March 2025, Respondent filed an inventory.33 She

copied Mr. Knothe’s entries concerning the Estate’s assets and value.34

Petitioner Files A Claim

On December 16, 2024, Petitioner filed a claim against the Estate.35

Counsel represented that it did so to compel a response from Respondent.36

Petitioner sent a copy of its claim and supporting documents to Respondent

on December 23, 2024.37

On the date of filing, the debt stood at $302,779.05.38 By the date of

the hearing, with continued accrued interest, the debt had grown to

32
Petition ¶ 12.
33
See generally Watson, ROW 186822 PJT, D.I. 29.
34
See Tr. at 23:8–10 (“I kind of just followed what [Mr. Knothe] put on there
because, like I said, I am unaware of any knowledge of how any of this goes.”).
Respondent has acknowledged that there were other Estate assets at the time of
Decedent’s death. See Tr. at 19:6–21:17. Respondent was not a fiduciary at that
time. I note that Respondent’s opening petition for authority did not simply copy
Mr. Knothe’s original petition. Compare Watson, ROW 186822 PJT, D.I. 18, with
Watson, ROW 186822 PJT, D.I. 22.
35
Petition ¶ 14.; see also Tr. at 101:12-22. The claim was not filed within eight
months of Decedent’s death, but this is not fatal because the Mortgage was recorded.
See 12 Del. C. § 2103.
36
Tr. at 101:19–22.
37
See PX 9. The enclosures to the letter are not included with the exhibit, but the
Court accepts the implied representation that they were enclosed with the original
letter Respondent received.
38
Petition Ex. A (Statement of Claim).
C.A. No. 2025-0063-DG
October 28, 2025
Page 9 of 18

$310,955.38.39 Respondent did not challenge the timing of the filing or

Petitioner’s evidence concerning the amount of the debt or the accrual of

interest.

The Hearing

I heard from two witnesses at the hearing, Respondent and Evan

Williams, an Asset Manager Team Lead at GitSit.40 In brief, Petitioner argued

that it presented Respondent with evidence of the Mortgage, and Respondent

could have corroborated the documents’ validity by looking at the filings at

the Register of Wills and the Register of Deeds.41 Petitioner argues that its

claim is valid and asks the Court to order Respondent to sell the Property.42

Respondent had the burden to prove that there is just cause to avoid a

court order to sell the Property.43 She attempted to meet that burden by

39
Tr. at 61:3–6.
40
Id. at 59:5–7. Mr. Williams has been employed by GitSit for seventeen years. Id.
at 59:8–10. The Court found Mr. Williams to be a knowledgeable and credible
witness.
41
Id. at 95:11–16 (“The stamped and recorded documents have been provided to
Ms. Moorefield. She has had the opportunity to look at documentation with her own
eyes at the Register of Wills, with the Recorder of Deeds, and she either has not
done so or has chosen not to do so.”). See also id. at 93:23–94:1 (“She refuses to
accept the valid legal documents that she has been presented with on multiple
occasions.”).
42
See id. at 95:10–22.
43
See 12 Del. C. § 2702.
C.A. No. 2025-0063-DG
October 28, 2025
Page 10 of 18

proving that Petitioner’s claim is invalid,44 based on alleged defects in the

documents45 and misuse of the estate administration process.46 Finally,

Respondent testified to her history with and sincere desire to keep the

Property. In addition to assessing the evidence concerning Petitioner’s

documents, I have synthesized Respondent’s affirmative arguments with her

answers on cross and consider them collectively as a request that the Court

exercise discretion to decline to order a sale of the Property under Title 12,

Section 2717 of the Delaware Code.47

44
See Tr. at 51:16–19 (stating belief that claim is invalid).
45
See generally id. 71:5–87:12 (examining Mr. Williams about alleged defects in
the Mortgage and assignment documents). Respondent also asserted that Petitioner
failed to provide certain required notices. Id. at 114:4–19. Respondent did not
develop the argument or examine Petitioner on the subject.
The Court notes that Respondent submitted Exhibits A–F to Petitioners and the
Court shortly before the original hearing date, but they were not placed on the docket
at that time. Respondent questioned Mr. Williams about Exhibits A–C, but the
Court failed to ask Respondent if she wished to move their admission. The same
documents were included in Petitioner’s Exhibits.
46
Id. 114:4–19.
47
Respondent did not cite this statute in her papers or at the hearing, but this appears
to be the closest potential match for Respondent’s argument. Section 2717 allows
this Court to decline to “order [the] sale of real estate . . . , if under the circumstances
it is considered improper that such sale should be made, although it should
sufficiently appear that the personal estate is not sufficient for the payment of the
debts, or that the sale was regularly conducted.” See 12 Del. C. § 2717.
C.A. No. 2025-0063-DG
October 28, 2025
Page 11 of 18

Synthesis and Assessment

Respondent has been skeptical of Petitioner’s supporting documents.48

She stated at least twice that she had no evidence that Decedent had taken out

a loan, despite being presented with the Mortgage and assignment records.49

This is partly because of the surrounding circumstances, discussed below, but

Respondent also questioned Mr. Williams about perceived defects in the

documents supporting Petitioner’s claim.50

Respondent asked Mr. Williams why two mortgages were executed on

the same date with the same number and why only one of the mortgages was

48
See, e.g., Tr. 81:4–15; 105:24–106:4; 106:12–14.
49
See, e.g., id. 106:1–3 (“I don't have any proof besides the documents, you know,
stating that there was a loan.”); 106:12–14 (“I didn't have any evidence of any
transfer or anything … saying that my grandfather even got the loan.”). Yet,
Respondent understood at some period of time that “the bank might own the
[Property][.]” Id. at 109:9–13 (relaying comments from Respondent’s uncle);
109:22–23 (thinking, after finding locks changed, “either my uncle has sold it or the
bank has come to collect on it.”).
50
The Court notes that Respondent raised briefly with Mr. Williams the matter of
notices allegedly required but not provided. See id. 81:4–15 (asserting that she did
not receive evidence of the loan); 106:3–4 (stating “there were … some key points
missing from the loan.”). The Court also notes that Respondent submitted a
purported “exhibit” listing other subjects of concern that she did not support with
argument or raise with Mr. Williams. Assuming, arguendo, that those arguments
were “raised,” the Court now considers them waived. See Tr. at 82:4–5 (“Do you
want to keep asking questions of Mr. Williams or are you ready to turn to the next
phase?”); 84:3–5 (“Ms. Moorefield, if you do not have more questions for Mr.
Williams, we can all stay together and talk about what happens next.”).
C.A. No. 2025-0063-DG
October 28, 2025
Page 12 of 18

found to have been satisfied.51 Mr. Williams testified that having a second

mortgage is standard industry practice, and that it exists to protect HUD.52 He

explained that the second mortgage was marked satisfied because HUD had

not been required to step in and fulfill the first bank’s obligation to disburse

the principal to Decedent.53

Respondent also challenged the validity and effectiveness of the

assignment documents. Respondent questioned Mr. Williams about missing

dates on the allonges, which suggested the possibility of fraud.54 Mr. Williams

testified that allonges are not required to be dated and that the undated

allonges in this case reflect standard industry practice.55 Respondent asked

why HUD was able to transfer the debt if HUD’s mortgage had been marked

satisfied, 56 why GitSit acted for HUD,57 and why GitSit was “allowed to sign

51
Tr. at 71:5–15.
52
See id. at 68:3–69:7.
53
See id. at 71:16–72:12.
54
See id. at 74:7–78:10. Respondent noted that, without a date, she “could put [an
undated allonge] on [her] printer and type [it] up.” Id. at 78:8–10.
55
See id. at 69:9–70:10; 76:3–79:4.
56
See id. at 73:6–7.
57
Respondent misunderstood this to mean that HUD was GitSit’s agent, not the
other way around. See id. at 72:19–21.
C.A. No. 2025-0063-DG
October 28, 2025
Page 13 of 18

[the debt] over to [itself.]”58 Mr. Williams explained that GitSit acted for

HUD by virtue of the POA and that the POA exists for HUD’s convenience.59

HUD receives large quantities of mortgages and does not want to be

responsible for signing to release them.60 Mr. Williams testified that the

arrangement gives Petitioner no benefit aside from being able to “release

HUD’s security in the home.”61

In addition to attacking Petitioner’s documents, Respondent gave

testimony about her perspective on the events relating to the Property, as well

as her history with and sincere attachment to the Property. Respondent was

surprised to learn that Decedent’s son had not probated the Estate at the time

of Decedent’s death.62 She was skeptical that a stranger to Decedent would

58
Id. at 73:21. This was Respondent’s perception of the documents. See id. at
72:15–74:6.
59
See id. at 73:8–14. The POA is recorded. See id. at 74:1–6.
60
Id. at 73:11–16.
61
Id. at 73:14–19.
62
See id. at 13:24–14:3 (“From my understanding, my uncle was supposed to handle
all the affairs.”); 22:12–15 (“I assumed after three years th[e] [Estate] would be
closed. And . . . I assumed that my uncle took care of what he needed to take care
of as far as that.”).
C.A. No. 2025-0063-DG
October 28, 2025
Page 14 of 18

be permitted to open his Estate.63 The delay between Decedent’s death and

Petitioner’s actions also raised concerns.64

The Property is Respondent’s childhood home.65 Respondent wants to

keep the Property, and she gave testimony about her recent efforts to take

responsibility. Respondent has visited the Property and paid associated bills

with her personal funds.66 She made overtures to Petitioner to acquire the

Property. 67 Respondent’s strong emotional attachment to the Property was

evident at the hearing.

63
Id. at 85:6–8; 86:15–18.
64
Id. at 114:5–10 (“[I]f any of this was supposed to occur after he passed away, why
did it take up to three years for anyone to come and make me aware or make the
estate aware of any of this?”).
65
Id. at 106:8–9 (“This is my childhood home. I’ve never seen myself without it.”).
Respondent testified that Decedent wanted the Property to be “the family house.”
Id. at 109:9–11. Petitioner did not object to this testimony. It is not necessary to my
recommendations in any event.
66
Respondent has been visiting the Property and paying for upkeep. See id. at 12:1–
13:21. It is not clear how or when Respondent obtained access to the Property. Cf.
id. at 109:19–21 (“[A]fter he passed away, I was still[] going to the house. And then
when I came there one day, the locks were changed.”).
67
Respondent proposed a payment plan, which Petitioner rejected. Id. at 49:13–17;
see also Response to the Petition for an Order for a Rule to Show Cause
(“Response”), D.I. 17 ¶ 17 (“I offered to start making repayment of the debt if able
to keep the Property as I was unaware that [there] was maybe debt until after
[Decedent’s] passing[.]”). Respondent later sent a “Tender of Payment.” Response,
D.I. 18. Respondent appears to have misunderstood the requirements for and
implications of using the latter instrument. Tr. at 48:5–22; 50:5–52:8.
C.A. No. 2025-0063-DG
October 28, 2025
Page 15 of 18

I conclude that Respondent petitioned to become administrator of the

Estate both to act responsibly where other family members appear to have

failed and because she perceived it to be a way she might avoid a sale of the

Property. Understandably, Respondent struggled to make sense of the legal

landscape on both fronts.68

I understand why a layperson might be skeptical that a stranger to a

family could open an estate years after a death and assert a claim to an asset.

Petitioner provided supporting documents, but they are not easily

decipherable by a layperson.69 I understand why a layperson would want to

test the legitimacy of a claimant’s documents before walking away.

68
Respondent has no prior experience with mortgages. Tr. at 57:17–19. She has
never administered an estate. Id. at 10:13–16. She is unfamiliar with the executor’s
role and purpose of the inventory. See, e.g., id. at 22:16–23:10 (discussing nature
of inventory and Respondent’s role); 16:11–17:23 (Respondent believed uncle to be
the estate representative); 32:19–23 (Respondent has not considered amending
inventory); 42:21–43:16 (Respondent unaware that Mr. Knothe was Estate
representative). Respondent also testified to her limited familiarity with financial
and real estate assets. See id. at 81:4–83:20. She did not appear to fully understand
her “Tender of Payment.” See id. at 49:21–52:1.
69
Mr. Williams noted at several points that the mortgage process and documents
are difficult for the uninitiated to understand. See, e.g., id. at 74:10–76:7 (testifying
to lack of break in assignment chain and conceding that explanation is “incredibly
complex”); 78:4–17 (explaining industry practice regarding allonges and describing
concepts as “abstract”); 82:20– 83:20 (stating that many family members have
questioned the recording of two mortgages and that he had similar questions when
he was new to his field).
C.A. No. 2025-0063-DG
October 28, 2025
Page 16 of 18

Nevertheless, Respondent did not call the validity of the Mortgage and

assignments into serious question, and she has not convinced me that there is

any just cause to decline to order the sale of the Property. Ultimately, the law

is not on Respondent’s side. Decedent entered into a reverse mortgage in

exchange for up to $288,000 to use during his lifetime.70 Decedent agreed

that, upon his death, the noteholder would have an immediate right to claim

ownership of and sell the Property.71 This is the only remedy Petitioner has

under the contract.72

Based on the foregoing findings, I conclude that the Estate’s assets are

insufficient to pay its debts.73 I recommend that the Court require Respondent

to sell the Property to satisfy Petitioner’s claim.74

70
See generally Mortgage and related documents.
71
See id. at 10 ¶ 9.
72
See id. at 12 ¶ 10 (“Lender may enforce the debt only through sale of the
Property.”). Foreclosure is an available non-contract remedy, but Petitioner elected
not to pursue that path for reasons Mr. Williams explained at the hearing. Tr. at
85:14–86:3. Requiring Petitioner to pursue that path now would impose delays and
costs that would be unfair. See id. at 67:1–7; 103:2–10.
73
There are additional Estate assets, but as described at the hearing, there is no
reason to believe that they would have sufficient value to enable the Estate to pay
Petitioner’s claim. See Tr. at 20:14–18 (uncle may have jewelry); 21:1–4
(describing furniture in storage).
74
If Petitioner intended to make an oral motion for fees and costs, I decline to
consider that motion at this stage. See id. at 95:3–9. I note that the Petition did not
include a request for fees. See D.I. 1.
C.A. No. 2025-0063-DG
October 28, 2025
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Next Steps

It appears that a sale of the Property can proceed promptly because

there is a potential buyer. In September 2024, Mr. Knothe entered into a

contract to sell the Property to a third party, Mr. Pizano.75 At the hearing, Mr.

Williams testified that Mr. Pizano, and his realtor, recently confirmed Mr.

Pizano’s continued willingness to buy the Property.76 Petitioner’s counsel,

likewise, represented that Mr. Pizano’s realtor had confirmed his client’s

continued interest in the Property.77 Counsel suggested that this path would

be desirable because it is likely to be easiest.78 He also suggested that there

may be legal liability for the Estate if the sale is not pursued.79 I make no

findings concerning the contract or any potential for liability.

It would be in both parties’ interest to sell the Property in a simple and

efficient manner. If a sale to Mr. Pizano under the September 2024 contract

is available and is efficient the parties may attempt to move forward with that

75
See generally Petition Ex. C (contract of sale).
76
Tr. at 63:10–15.
77
Id. at 98:22–99:4.
78
Id. at 97:7–8. At other times, he indicated that a simple order compelling a sale
of the Property would be satisfactory. See id. at 98:2–5.
79
Id. at 54:19–55:18. On the other hand, counsel also suggested that the potential
buyer is not likely to devote resources to this course of action. Id. at 98:6–9.
C.A. No. 2025-0063-DG
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Page 18 of 18

opportunity. If problems should arise in connection with that sale, I am

hopeful that the parties will work together to find a suitable alternative.

Conclusion

For the reasons stated in this Report, I conclude that Respondent must

sell the Property to satisfy Petitioner’s claim. Respondent must present to the

Court as soon as reasonably possible a petition to sell the Property that

complies with Title 12, Section 2701 of the Delaware Code.

This is a Final Report. Any party wishing to file exceptions must do so

within 11 days and follow Court of Chancery Rule 144.

IT IS SO ORDERED.

Very truly yours,
/s/ Danielle Gibbs
Magistrate in Chancery