IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS ROCKFORD DIVISION ILLINOIS DEBT ACQUISITION COMPANY, L.L.C., Plaintiff, v. EL PASO HCC, LLC, et al. Defendants. Case No. 3:24-CV-50034 Judges Honorable Iain D. Johnston and Honorable Margaret J. Schneider NOTICE OF PUBLIC SALE PUBLIC NOTICE is hereby given that pursuant to 28 U.S.C. Secs. 2001 and 2002, the Order Appointing Receiver entered on January 25, 2024 (Dkt No. 8) entered in the above captioned matter and the July 18, 2025 Order setting sale procedures for the sale of Defendants' assets (Dkt. No. 129), the Court's Receiver shall, with the assistance of Intercounty Judicial Sales Corporation (Intercounty), place for public sale to the highest bidder, the real and personal property more fully described below and more fully described in the Verified Complaint in the above captioned matter (Dkt No. 1 and incorporated herein by reference) on October 10, 2025 at the hour of 12 Noon, CDT, through hybrid means via Zoom (Zoom Instructions) and in person in the Lobby of U.S. Courthouse, 327 South Church Street, Rockford, IL 61101: Real Property: The real property commonly known as 850 East 2nd Street, El Paso, IL 61738, operating as El Paso Health Care Center, a 123-bed licensed skilled nursing facility, which is at issue in and more fully described in the Verified Complaint in the above captioned matter (Dkt. No. 1). The real property commonly known as 201 East Falcon Highway, Flanagan, IL 61740, operating as Flanagan Rehab & Health Care Center, a 75-bed licensed skilled nursing facility, which is at issue in and more fully described in the Verified Complaint in the above captioned matter (Dkt. No. 1). The real property commonly known as 141 South Junior Avenue, Kewanee, IL 61443, operating as Courtyard Estates of Kewanee, a 35-bed licensed assisted care living facility, which is at issue in and more fully described in the Verified Complaint in the above captioned matter (Dkt. No. 1). The real property commonly known as 415 East Main Street, Knoxville, IL 61448, operating as Courtyard Estates of Knoxville, a 32-bed licensed assisted care living facility, which is at issue in and more fully described in the Verified Complaint in the above captioned matter (Dkt. No. 1). The real property commonly known as 1200 West Broadway, Monmouth, IL 61462, operating as Legacy Estates of Monmouth, a 59-bed licensed assisted care living facility, which is at issue in and more fully described in the Verified Complaint in the above captioned matter (Dkt. No. 1). The real property commonly known as 275 East Carl Sandburg Drive, Galesburg, IL 61401, operating as Marigold Rehab & Health Care Center, a 172-bed licensed skilled nursing facility, which is at issue in and more fully described in the Verified Complaint in the above captioned matter (Dkt. No. 1). The real property commonly known as One Courtyard Boulevard, Monmouth, IL 61462 operating as Courtyard Estates of Monmouth, a 51-bed licensed assisted care living facility, which is at issue in and more fully described in the Verified Complaint in the above captioned matter (Dkt. No. 1). The real property commonly known as 703 East Buffalo Street, Polo, IL 61064, formerly operating as Polo Rehab & Health Care Center, an 81-bed licensed skilled nursing facility, which is at issue in and more fully described in the Verified Complaint in the above captioned matter (Dkt. No. 1). Polo Rehab & Health Care Center is currently not operating. Personal Property: All personal property that is pledged by the Defendants as collateral, which is at issue in and more fully described in the Verified Complaint in the above captioned matter. (Dkt. No. 1). Terms of sale are outlined in the July 18, 2025 Order setting sale procedures for the sale of Defendants' assets (Dkt. No. 129) Additional Sale terms. Bidders may contact either Intercounty or the Receiver's attorneys to receive Zoom login instructions prior to the sale. Bids shall be submitted to the Receiver on the day of the sale and shall include a signed asset purchase agreement from the bidder and a redline of the bidder's asset purchase agreement to the stalking horse bidder's asset purchase agreement. All bids (other than the stalking horse bid) must be in the form of an all cash bid in an amount that exceeds the stalking horse bid by at least two percent (2%) of the stalking horse bid of $18,150,000.00, plus a minimum overbid of an additional $200,000.00 (i.e. $18,713,000.00). All bids must be irrevocable and may not be subject to conditions or financing contingencies. The asset purchase agreement must include the proposed closing date, all final terms of the bid and all schedules thereto. All bids must include sufficient information, as reasonably determined by the Receiver, to allow the Receiver to determine, in his reasonable business judgment, whether the interested party has the financial wherewithal to consummate the sale. The winning bidder will be required to deposit in a sum equal to ten percent (10%) of the purchase price contained in the accepted offer accepted by Receiver to the Receiver's designated title company within seven (7) business days after notification of acceptance. Pursuant to the Order entered in the above captioned matter on July 18, 2025 as Dkt. No. 129, at the public sale, Intercounty shall hold an auction whereat bidders that complied with the requirements set forth in the foregoing paragraph 6 of the Order entered in the above captioned matter on July 18, 2025 as Dkt. No. 129 starting with the highest and best bid submitted in compliance with paragraph 6 of the Order entered in the above captioned matter on July 18, 2025 as Dkt. No. 129, which highest and best bid shall be determined by Receiver. Bidders who complied with the requirements set forth in the foregoing paragraph 6 of the Order entered in the above captioned matter on July 18, 2025 as Dkt. No. 129 shall be permitted to submit topping bids at the auction until Intercounty and Receiver determine the final and best bid (the "Winning Bid"), and, if multiple bids are submitted, a back-up bid (the "Back-up Bid"). The accuracy of the information solicited by bidders cannot be guaranteed, and prospective bidders are therefore encouraged to complete any desired and non-invasive due diligence at their own expense. The sale of the Receivership Assets is without recourse to Receiver and in "AS-IS" condition, and in any event any sale will otherwise be consistent with the sale procedures approved in the above referenced matter. The sale is further subject to confirmation by the Court in the above captioned matter. Any expenses associated with the sale also will be subject to and presented to the Court in the above captioned matter for approval. Prospective bidders are admonished to check the Court file in the above captioned matter to verify all information. Prospective Bidders may contact Intercounty and or the Receiver's attorneys for Zoom Instructions. Property tours will be available to all interested bidders at times to-be-scheduled with the Receiver, and the Receivership Assets may also be shown by appointment. Receiver will provide information related to the Receivership Assets for review to prospective bidders, including subject to a confidentiality agreement. To arrange a tour of the facilities or for further information concerning the real and personal properties, interested parties may contact the Receiver through his counsel(s) at Scott & Kraus, LLC: Eugene S. Kraus Jason R. Sleezer Scott & Kraus, LLC 150 S. Wacker Drive, Suite 2900 Chicago, IL 60606 (312) 327-1050 ekraus@skcounsel .com jsleezer@skcounsel.com I3272824