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COURT OF COMMON PLEAS BERKS COUNTY, PA No. 25-09489 UNIVEST BANK AND TRUST CO., Plaintiff, v. GDM LEASING INC., Defendant. COURT OF COMMON PLEAS BERKS COUNTY, PA No. 25-09457 UNIVEST BANK AND TRUST CO., Plaintiff, v. GBD REAL ESTATE, LLC, Defendant. COURT OF COMMON PLEAS BERKS COUNTY, PA No. 25-09509 UNIVEST BANK AND TRUST CO., Plaintiff, v. KINLEY MOTOR CARS LLC, Defendant. COURT OF COMMON PLEAS BERKS COUNTY, PA No. 25-09387 UNIVEST BANK AND TRUST CO., Plaintiff, v. KINLEY AUTOMOTIVE GROUP, INC., Defendant. NOTICE OF MOTION FOR ENTRY OF AN ORDER (I) APPROVING THE SALE OF SUBSTANTIALLY ALL OF GBD REAL ESTATE, LLC’S ASSETS; (II) AUTHORIZING THE SALE OF SUCH ASSETS FREE AND CLEAR OF LIENS, CLAIMS AND ENCUMBRANCES AND OTHER INTERESTS; (III) AUTHORIZING AND APPROVING THE PURCHASE AND SALE AGREEMENT BETWEEN RECEIVER AND BLAC HOLDINGS II, LLC; (IV) AUTHORIZING THE RECEIVER’S DELIVERY OF A DEED IN FAVOR OF PURCHASER WITH RESPECT TO THE REAL PROPERTY AND (V) GRANTING RELATED RELIEF TO:ALL POTENTIALLY INTERESTED PARTIES IDENTIFIED BY RECEIVER OR HIS ADVISORS; COUNSEL FOR PURCHASER; COUNSEL FOR GBD; GBD’S KNOWN CREDITORS; ALL PARTIES IN INTEREST WHO HAVE REQUESTED NOTICE; ALL PARTIES WHO ARE KNOWN TO POSSESS OR ASSERT A LIEN, CLAIM, ENCUMBRANCE OR INTEREST IN OR UPON THE PROPERTY; AND ALL APPLICABLE FEDERAL, STATE AND LOCAL REGULATORY OR TAXING AUTHORITIES OR RECORDING OFFICES WHICH ARE KNOWN BY THE RECEIVER TO HAVE AN INTEREST IN THE RELIEF REQUESTED IN THE MOTION; COUNSEL TO WHWF, LLC D/B/A FIVE RIVERS DEVELOPMENT. Edward A. Phillips (“Receiver” or “Seller”), the appointed receiver for GBD Real Estate, LLC (“GBD”), among others, pursuant to the Order of the Court dated August 11, 2025 (the “Receivership Order”), has filed a Motion for Entry of an Order (I) Approving the Sale of Substantially All of GBD’s Assets (the “Sale”); (II) Authorizing the Sale of Such Assets Free and Clear of Liens, Claims and Encumbrances and Other Interests; (III) Authorizing and Approving the Purchase and Sale Agreement (the “Purchase Agreement”) Between Receiver and Blac Holdings II, LLC (the “Purchaser”); (IV) Authorizing the Receiver’s Delivery of a Deed in Favor of Purchaser with Respect to the Real Property (as defined in the Purchase Agreement); and (V) Granting Related Relief (the “Motion”). If you seek to object or otherwise respond to the Motion, the Sale of the Property to Purchaser, or to the Purchase Agreement, you must file your response or any objections on or before November 21, 2025 at 4:00 p.m. (prevailing Eastern Time) in writing, with the Court of Common Pleas for Berks County, Berks County Courthouse, 633 Court Street, Reading, PA 19601, Attn: Chambers of Judge J. Benjamin Nevius. You may obtain a copy of the Motion by contacting the attorneys for Receiver. At the same time, you must also serve a copy of the response/objection upon the following: (i) attorneys for Receiver, Blank Rome LLP, One Logan Square, 130 North 18th Street, Philadelphia, PA 19103, Attn: Michael B. Schaedle, Esq. (mike.schaedle@blankrome.com), Brian S. Paszamant, Esq. (brian.paszamant@blankrome.com), and Lawrence R. Thomas III, Esq. (lorenzo.thomas@blankrome.com); (ii) attorneys for Purchaser, Barley Snyder, 2755 Century Boulevard, Wyomissing, PA 19610, Attn: Eden R. Bucher, Esq. (ebucher@barley.com); and (iii) attorneys for Univest, Stradley Ronon Stevens & Young, LLP, 2005 Market Street, Suite 2600, Philadelphia, PA 19103, Attn: Julie M. Murphy, Esq. (jmmurphy@stradley.com) and Daniel M. Pereira, Esq. (dpereira@stradley.com). A HEARING ON THE MOTION AND THE PROPOSED SALE WILL BE HELD ON DECEMBER 2, 2025 AT 1:30 P.M. (PREVAILING EASTERN TIME). IF YOU FAIL TO RESPOND IN ACCORDANCE WITH THIS NOTICE, THE COURT MAY GRANT THE RELIEF REQUESTED WITHOUT FURTHER NOTICE OR HEARING. -------------------------------------- 1Capitalized terms used but not defined herein shall have the meanings ascribed to them in the Motion RE Oct 24, 31 Nov 7 a-1