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Case 10- 03623 -AJC Doc 179 Filed 04/29/15 Page 12 of 16 <br />settled or been resolved through the claims objection process. As such, Plaintiff requests that <br />Defaults also be entered against the Secured Claimants and the John Does. <br />Defendants Interests in the Proceeds of the Sale of the <br />Bueno and Black Rose Minim Properties <br />32. Requiring the Defendant to have proven the validity, priority or extent of their <br />purported liens, claims, encumbrances, or interests was and is necessary to, (a) ensure that <br />payment to a Defendant upon adjudication of their interests is warranted, proper, in the correct <br />amount, and will discharge their interests, (b) assure the ultimate purchaser and the title <br />insurance company insuring title, that a Debtor who is a seller of its own interest has paid, <br />discharged or provided adequately for the payment and discharge of all interests, (c) ensure that <br />marketable, or acceptable, title can be conveyed by Debtors to the ultimate purchaser of the <br />Bueno and Black Rose Mining Properties, free and clear of all liens, claims, encumbrances, and <br />interests, including anyone laying claim to an ownership interest in the Bueno and Black Rose <br />Mining Properties, and (d) assure compliance with the Sale Procedures in the Sale Motion. <br />33. All Defendants, except for Worldwide who has been paid on its interest, failed to <br />prove the validity, priority, or extent of their liens, claims, encumbrances, or interests in the <br />Bueno and Black Rose Mining Properties, and as such are precluded from receiving distribution <br />of proceeds from the sale or other disposition thereof. <br />34. With the exception of Worldwide, none of the Defendants have proven the <br />validity, priority or extent of their respective liens, claims, encumbrances, and interests, <br />including disputed ownership interests, pursuant to 11 U.S.C. §363(p)(2) in order to determine <br />the amount of the distribution they would have been entitled to receive from the net proceeds <br />from the sale of the Bueno and Black Rose Mining Properties, after costs and expenses of such <br />12 <br />