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Case 10- 03623 -AJC Doc 179 Filed 04/29/15 Page 14 of 16 <br />in escrow pending the determination by this Court herein that no other Defendants hold any <br />interests in such property. <br />39. The Trustee requests that the Court enter an order within the Final Declaratory <br />Judgment that the Trustee is now free to release the amounts she has held in escrow in order to <br />make distributions upon all allowed administrative and creditor claims in this case. <br />40. The Trustee requests that the Court determine that no Defendants, who either <br />asserted and/or held any claims or interests in one or more of the Bueno and Black Rose Mining <br />Properties, including any liens, encumbrances, security interest, mortgages, tax liens, or <br />judgments or a claim secured by one or more of the foregoing, attempted to prove by answer, <br />claim, adversary proceeding, or motion, the validity, priority, or extent of their Liens and <br />Encumbrances in accordance with the requirements of §363(p)(2), and that no such Defendants, <br />other than Worldwide, who has already been paid on its interest, hold any such interest in the <br />Bueno and Black Rose Mining Properties or the proceeds from their sale. <br />Wherefore, Plaintiff/ Trustee requests the entry of a Final Default Declaratory Judgment, <br />in the proposed form attached as Exhibit A hereto, granting the relief sought by Plaintiff in this <br />Motion, and the Second Amended Complaint, and for such further relief as this Court deems just <br />and proper. <br />Dated: April 29, 2015 Respectfully submitted, <br />GRAYROBINSON, P.A. <br />Attorneys for Plaintiff Marcia Dunn, Chapter 7 Trustee <br />401 E. Las Olas Boulevard, Suite 1000 <br />Fort Lauderdale, FL 33301 <br />Phone 954- 761- 8111/Fax 954- 761 -8112 <br />By: /s/ Ivan J. Reich <br />Ivan J. Reich, Esq. <br />Florida Bar No. 778011 <br />ivan.reichna, rgray- robinson.com <br />14 <br />