IN RE: KEVIN P. O’DONNELL CHAPTER 7, Debtor.

CASE NO: 06-18497-DWK.United States Bankruptcy Court, D. Maryland, (Baltimore Division) Salisibury.
April 17, 2007

STIPULATION AND CONSENT ORDER AUTHORIZING SALE OF REAL PROPERTY
E. DERBY, Bankruptcy Judge

Upon Consideration of the consents of Michael G. Rinn, Trustee of the Bankruptcy Estate of Kevin P. O’Donnell (“Trustee”) Heidi O’Donnell (“Co-Owner”), a co-owner as tenants in severalty of the real property and improvements described and known a 9317 Ten Point Court, Berlin, Maryland 21811 (the “Real Property”) as evidenced by their signatures or the signatures of their respective counsel, to the entry of an Order in the following format authorizing the sale by the Trustee of Debtor’s and the co-owner’s interest in and to the Real Property pursuant to 11 U.S.C. 363(h) upon the following terms and conditions, it is; after prior Notice of Proposed Sale (the “Notice’), and without opposition, by the United States Bankruptcy Court for the District of Maryland

ORDERED, that Michael G. Rinn, Trustee, shall be and hereby is authorized to offer, sell, and convey the interest of the Debtor and the interest of co-owner Heidi O’Donnell in and to the Real Property and to consummate closing of the said Real Property, pursuant to 11 U.S.C. § 363(h) upon the terms set forth in the Notice and the following terms;

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a. TYPE OF SALE: Private negotiated Sale

b. PROPERTY TO BE SOLD: 9317 Ten Point Court, Berlin, Maryland 21811.

c. PURCHASE PRICE: $440,000.00.

d. BUYERS: Lenore A. Bennett, a disinterested third party.

e. PLACE AND TIME OF SALE: As soon after Court approval as is practicable.

f. REALTOR COMMISSIONS: 6%.

g. TRUSTEE’S COMMISSIONS: As allowed by Court, voluntarily capped at
$18,750.00

The Co-owner hereby specifically acknowledges that the Real Property was offered to the Co-owner pursuant to 11 U.S.C. 363(i) and that the Co-owner hereby irrevocably waives the right to purchase the Real Property and consents to the consummation of the sale of the Real Property on the terms set forth in the Notice and herein.

Disposition of Proceeds in the following order:
The sales proceeds from the sale of the Real Property shall be disbursed by the Trustee in the following order from available funds:

1.) The unavoidable liens of lienholders if any, against said property, shall be transferred to and paid from the proceeds of the sale at closing, in the same priority and amount of said lien, mortgage, or security interest attached to the subject property, subject to the agreement of the parties; then

2.) The actual cost and expenses of any sale of said assets, specifically including but not limited to realtor commissions, charges, fees, and disbursements necessary for the conveyance and transfer of the property or assets, shall be payable and paid from the proceeds of sale; then

3.) Trustee’s commissions, voluntarily capped at the sum of $18,750.00[1] , and expenses including expenses provided for under 11 U.S.C. § 503 as allowable pursuant to Order of the Bankruptcy Court, shall be calculated on the gross sale proceeds to be received then segregated pending Application and approval of such commissions and expenses by further Order of this Court after subsequent Notice, the Co-owner specifically authorizing the Trustee to seek commissions on the gross sales proceeds up to the reduced sum of $18,750.00; then

4.) The undisputed, allowable joint unsecured debts of the Debtor and the Co-owner

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Heidi O’Donnell on a pro rated basis; including[2] :

Creditor Account Amount to be paid from
joint sale proceeds

i. Commonwealth One FCU #131180 not to exceed $14,400.00

ii. Capital One #4874 not to exceed $19,500.00

iii. AT T Universal #9812 not to exceed $9,000.00

iv. MBNA/. Bank of America #2609 not to exceed $7,000.00

v. CitiCorp #1801 not to exceed $16,900.00

vi. Chase Account #3825 or not to exceed $2,600.00
5539 then

5.) The remaining sales proceeds, if any, shall be distributed by and between the estate and the co-owner of the property according to the interest of the estate and said co-owner; then

6.) Thereafter, the proceeds paid to the Estate, if any, shall be distributed by the estate in accordance with the provisions of 11 U.S.C. including the payment of allowed unsecured claims entitled to priority pursuant to 11 U.S.C. 507(a)(1)(A).

The Foregoing Consented to:

/s/Michael G. Rinn, Esquire /s/Ann Shaw, Esquire
111 Warren Road, Suite 4 P.O. Box 448
Cockeysville. Maryland 21203 Salisbury, Maryland, 21803-0448
(410) 683-1040 (410) 742-9171
Trustee/Counsel to Trustee Counsel to Heidi O’Donnell

SO ORDERED

[1] The Trustee pursuant to 11 U.S.C. would be entitle to seek maximum commissions, based on the proposed sale price of $440,000.00 of $24,877.00
[2] The Debtor and the co-owner, by Voluntary Separation Agreement dated October 26, 2005 identified and directed the payment of the listed joint unsecured debts.