20-11723-mg Doc 342 Filed 12/07/20 Entered 12/07/20 18:02:10 Main Document Pg 1 of 4 UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF NEW YORK

In re: Chapter 11

K.G. IM, LLC, et al.,1 Case No. 20-11723 (MG)

Debtors. (Jointly Administered)

AFFIDAVIT OF SERVICE OF PUBLICATION

PLEASE TAKE NOTICE that the undersigned certifies that the following document

Notice of Auction and Sale Hearing [Docket No. 269]

was published in the following publication on the date provided.

Publication Date Exhibit The New York Times October 30, 2020 A

/s/ Darleen Sahagun____ Darleen Sahagun Omni Agent Solutions 5955 DeSoto Avenue, Suite 100 Woodland Hills, California 91367 (818) 906-8300 Claims, Noticing, and Administrative Agent for the Debtor

1 The Debtors in these chapter 11 cases, along with the last four digits of each Debtor’s federal tax identification number (if any), include: K.G. IM, LLC (8556); Il Mulino USA, LLC (1682); IM LLC – III (2613); IMNYLV, LLC (9805); IM NY, Florida, LLC (9385); IM NY, Puerto Rico, LLC (0901); IMNY AC, LLC (5082); IM Products, LLC (0303); IM Long Island Restaurant Group, LLC (1623); IM Long Island, LLC (1488); IM Franchise, LLC (0565); IM 60th Street Holdings, LLC (9997); IM Broadway, LLC (4335); IMNY Hamptons, LLC (0423) and IM Payroll, LLC. For the purpose of these chapter 11cases, the service address for the Debtors is: 1761 Yardley Langhorne Rd Yardley PA 19067. 20-11723-mg Doc 342 Filed 12/07/20 Entered 12/07/20 18:02:10 Main Document Pg 2 of 4

EXHIBIT A

20-11723-mg Doc 342 Filed 12/07/20 Entered 12/07/20 18:02:10 Main Document Pg 3 of 4 20-11723-mg Doc 342 Filed 12/07/20 Entered 12/07/20 18:02:10 Main Document C M Y K Nxxx,2020-10-30,B,005,Bs-BW,E1Pg 4 of 4

THE NEW YORK TIMES BUSINESS FRIDAY, OCTOBER 30, 2020 N B5

VIRUS FALLOUT | WORKPLACE

Right-Wing Pundit Draws a ‘Lot of Whos’ on Facebook Virus Briefing ENERGY FROM FIRST BUSINESS PAGE a frequent critic of Facebook and Exxon Mobil to Cut 1,900 Jobs posts every day. He appeared on other Silicon Valley tech compa- the lists more often than not, and nies, which he believes are cen- Under pressure from low oil and frequently trounced much better- soring conservatives. His own natural gas prices, Exxon Mobil known commentators like Sean posts have been flagged several said on Thursday it would cut Hannity and Ben Shapiro. (This times by Facebook’s third-party 1,900 jobs through voluntary and involuntary layoffs in the United month, for example, Mr. Bongino fact-checkers, and he said it was States in the next several months. has gotten nearly twice as many only a matter of time before the Exxon also said it is reducing Facebook interactions as Mr. social network cracked down on the number of contractors it uses Shapiro, despite having a much him more aggressively. smaller following.) around the world by 14,000 over “I’m anticipating being banned the next two years. These cuts fol- Mr. Bongino, 45, has become a from Facebook,” he said. “They’ll lightning rod on the left, both low large reductions by other oil ban me, or use some excuse to and gas companies. because of his growing audience throttle my page. It’s going to and because he has been criti- Exxon Mobil directly employs have nothing to do with facts. It’s more than 70,000 people and said cized for posting exaggerated going to be ideological.” and misleading information. He the new job cuts in the United It’s hard to square Mr. Bongi- was one of the most aggressive States would primarily be in its no’s concerns about right-wing promoters of “Spygate,” a dubi- Houston management office. censorship with the incredible ous conspiracy theory about an “These actions will improve the performance of his page. Still, he illegal Democratic plot to spy on company’s long-term cost com- is making backup plans. He has Mr. Trump’s 2016 campaign. He petitiveness and ensure the com- invested in Parler and Rumble, falsely claimed that masks are pany manages through the cur- “largely ineffective” at prevent- two start-ups building “free rent unprecedented market con- ing the spread of Covid-19, and speech alternatives” to Twitter dition,” the company said in a has promoted unproven claims and YouTube, respectively, and statement that cited the drop in about voter fraud as well as has begun posting his content energy demand because of the there as well as on the larger pandemic. CLIFFORD KRAUSS stoking fears about a Democrat- ROY ROCHLIN/GETTY IMAGES networks. led coup. (Mr. Bongino has Dan Bongino’s Facebook page has better numbers than The Times, The Washington Post and CNN combined. ENTERTAINMENT Mr. Bongino, who was recently claimed that he was merely Streaming Boom for Comcast repeating left-wing claims about found to have lymphoma, al- post-election violence.) millions of new followers just clip of maybe the president or QAnon, the pro-Trump conspir- lowed that Facebook had been a Comcast, the nation’s largest ca- ble operator and the owner of Plenty of people have fact- because their personas happen Kayleigh McEnany, and we’ll acy movement, grew in popular- “pretty good business partner,” NBCUniversal, passed a mile- checked Mr. Bongino. But no- to fit into the grooves of a plat- intermingle it with clips of my ity. (Mr. Bongino is not a QAnon despite his disagreements with stone that highlights the broad body has figured out what, ex- form’s algorithm. show, and it seems to work well promoter, but his content is the company’s fact-checkers. shift happening across the media actly, has lifted him above the Granted, Mr. Bongino’s shtick for us,” he said. “Wherever my popular with the movement’s And he maintained that he had industry: It now has more legions of other pro-Trump influ- is not exactly new. His brand of content is posted, we just get an supporters.) no secret sauce — no growth- streaming subscribers than ca- encers battling for attention right-wing pugilism is similar to incredible response.” Unlike Mr. Shapiro, whose hacking strategy, no shortcuts, ble-TV subscribers. online. what talk-radio hosts like Rush Along with his Facebook page, website, The Daily Wire, was no networks of unlabeled pages Limbaugh and Mark Levin have Mr. Bongino and a small team of caught using a network of affili- funneling clicks to his posts. About 22 million people signed I called Mr. Bongino the other up to its Peacock service since it day, hoping to learn something been doing for decades. He is writers keep up the Bongino ated Facebook pages to generate Mostly, he seems to be succeed- good at turning daily culture-war Report, a news aggregator traffic, Mr. Bongino swears he ing by catering to a large and started in April, the company re- about how he became Facebook’s ported Thursday as part of its biggest right-wing star. But he skirmishes into hyperpartisan started last year to cater to con- has “absolutely, categorically, 100 hyper-engaged audience of Face- outrage-bait, with a cast of recur- servatives who felt that the percent never” used any under- book conservatives, while being third-quarter results. That’s more said he had no idea, either. than double the figure it reported ring left-wing villains and right- Drudge Report had become too handed tactics to boost his Face- slightly more cautious than other “I don’t know what it is,” he at the end of July. wing heroes who inevitably show liberal. He puts out podcast book presence. right-wing pundits not to run said. “The strategy didn’t change The company’s foundational up to dunk on them. (Typical episodes and videos in which he “We don’t use bots,” he said. afoul of Facebook’s rules. He said at all. I think people just like the business — cable TV — now has headline: “CNN’s Fredo rants against the “deep state,” “We don’t even advertise much he didn’t even take advantage of message.” 19 million subscribers, a decline of SCHOOLED On His Brother’s decries the “Russia hoax,” and on Facebook.” A charming thing about social Facebook’s analytics tools, which 273,000 from the previous quar- media — or a terrifying one, Coronavirus Policies.”) And he is promotes spurious claims about He credits his popularity, in- allow creators to get a fine-tuned ter. That’s not a surprise: The depending on your perspective skilled at a certain type of indus- Hunter Biden’s laptop — all fairly stead, to Facebook’s older and sense of what their audience pay-TV industry has for years — is that it often creates stars trial-scale content production standard Fox News narratives, more conservative user base — wants to see. seen a steady drop, as customers who have no idea how they got that is valuable on today’s inter- repackaged for a Facebook audi- and to the writers who work for “If I told you I spent 10 min- cut the cord in favor of cheaper there. An Olympic gymnast or a net, flooding social media with a ence. him, who “have almost made a utes on analytics over the past streaming. world-class violinist follows a torrent of original posts, remixed Mr. Bongino’s popularity be- cottage industry” of understand- year, I’d be lying,” he said. “I Comcast reported overall reve- well-worn path, but every day, memes and videos and found gan to spike during this spring’s ing the platform’s algorithms, he have no idea who’s watching, I nue of $25.5 billion and profit of $2 YouTubers, TikTok stars and footage. Covid-19 lockdowns, as election said. just know it’s a whole lot of billion, beating expectations. Facebook pundits wake up to “We’ll take some interesting season began to heat up and Like Mr. Trump, Mr. Bongino is whos.” Like other cable operators, Comcast has emphasized its in- ternet service as it recognizes that pay television will become a smaller, less profitable arm of a A Founder Leaves The Intercept, Claiming He Was Censored bigger enterprise. The pandemic has only hastened that transfor- By KATIE ROBERTSON hemently supported by all New Agency documents leaked by the two-year investigation by the spe- Betsy Reed, the editor in chief of mation. As the country went into York-based Intercept editors in- former government contractor cial counsel Robert S. Mueller III The Intercept, disputed Mr. lockdown, Comcast benefited The national security journalist even more from the growth in in- and free speech advocate Glenn volved in this effort at suppres- Edward J. Snowden in 2013. At the into possible ties between Donald Greenwald’s claim that he had sion.” He added that the editors’ time of the leaks, Mr. Greenwald J. Trump’s 2016 presidential cam- been censored. “Glenn Green- ternet users and added 633,000 Greenwald has left The Intercept, customers during the three actions were “in violation of my worked for the United States edi- paign and the Russian govern- wald’s decision to resign from The the news website he helped create months ending in September, the contractual right of editorial free- tion of The Guardian newspaper, ment. Intercept stems from a fundamen- in 2013, claiming his work had most it has picked up in a single been censored. dom.” and the aggressive reporting he Mr. Greenwald’s writing on the tal disagreement over the role of Mr. Green- conducted with two colleagues, Mueller investigation was often at quarter. It now has about 28 mil- Mr. Greenwald, a former law- editors in the production of jour- wald later Ewen MacAskill and the docu- odds with reports by his Intercept lion broadband subscribers. yer, wrote a 3,300-word post on nalism and the nature of censor- posted on Sub- mentary filmmaker Laura colleagues. He has also become a EDMUND LEE the digital platform Substack on ship,” she wrote in a statement. stack what he Poitras, gave The Guardian US frequent guest on Tucker Carl- Ms. Reed added that his post on AIRLINES Thursday saying that he was leav- the Pulitzer Prize in service jour- called “the son’s prime-time program on Fox his departure was “teeming with United to Test Some Travelers ing the site because it had refused most recent nalism in 2014. News, usually a venue for conser- distortions and inaccuracies — all to publish an article he had writ- draft” of the ar- The articles on the N.S.A.’s do- vatives. On the show’s Oct. 22 For a month, beginning in No- of them designed to make him ap- ten on Joseph R. Biden Jr. and his ticle, which was mestic surveillance program episode, Mr. Greenwald took aim vember, United Airlines will test pear a victim, rather than a grown son, Hunter Biden, unless he headlined “The drew heavy criticism from the at what he said was “corruption passengers over the age of 2 for agreed to remove portions that Greenwald Real Scandal: American and British govern- that is absolutely pervasive in the person throwing a tantrum.” the coronavirus on select flights were seen as critical of the Demo- U.S. Media ments, with lawmakers saying U.S. news media,” accusing “top The statement included some from Newark Liberty Interna- cratic presidential nominee. Uses Falsehoods to Defend Joe Bi- that they had compromised na- newsrooms” of telling their re- qualified praise: “We have the tional Airport to Heathrow Air- In announcing his decision to den From Hunter’s Emails.” The tional security. They also made porters not to investigate the greatest respect for the journalist port in London, in a trial intended leave The Intercept, Mr. Green- article, in part, examined digital Mr. Greenwald something of a Hunter Biden emails and claims of Glenn Greenwald used to be, and to help convince government offi- wald said that the site’s editors data taken from a laptop comput- journalistic hero to many liberals. corruption against Joe Biden. we remain proud of much of the cials that testing could be a cru- “censored an article I wrote this er said to belong to the candidate’s In recent years, however, he has In a post on Thursday, Mr. work we did with him over the cial part of reopening interna- week, refusing to publish it unless son. alienated some of his former sup- Greenwald said he would contin- past six years,” the editor wrote. tional travel. I remove all sections critical of Mr. Greenwald is best known porters because of the skepticism ue to publish his work at Substack, “It is Glenn who has strayed from United will administer the rap- Democratic presidential candi- for his investigative journalism he has expressed in a number of a platform known for its subscrip- his original journalistic roots, not id molecular Abbott ID Now date Joe Biden, the candidate ve- based on National Security Intercept columns concerning the tion newsletters. The Intercept.” Covid-19 test to people flying be- tween Nov. 11 and Dec. 11 on Flight 14, departing at 7:15 p.m. on Mondays, Wednesdays and Fri- days from Newark. Passengers will have to test negative for the Apollo Chief Says Giving Epstein a Second Chance Was a ‘Terrible Mistake’ coronavirus to board the plane. People who do not want to take By MATTHEW GOLDSTEIN convicted of soliciting prostitution million, or $1.11 a share, in the peri- the test will be moved to another Leon Black, the billionaire private from an underage girl in 2008, Mr. $50 million in od, down from $363.3 million, or flight. equity executive whose financial Black said it had only been since $1.63 a share, a year earlier. “We believe the ability to pro- ties to Jeffrey Epstein have 2018 that he became aware of the payments to Epstein- But Apollo reported that total vide fast, same-day Covid-19 test- sparked questions from his pow- conduct that led federal authori- assets under management at the ing will play a vital role in safely erful clients, said Thursday that it ties to charge Mr. Epstein with sex related entities. firm, which specializes in using reopening travel around the had been a “terrible mistake” to trafficking last year. Mr. Epstein leverage and investor dollars to world,” said Toby Enqvist, chief give Mr. Epstein a second chance died in a Manhattan jail cell in Au- ters over to his co-founders Josh take over ailing companies, rose customer officer for United. In after his sex-crimes conviction in gust 2019; his death was ruled a Harris and Marc Rowan and other to $433 billion in the third quarter, September, international air ar- 2009. suicide. top executives. which was up from $413.6 billion in rivals to New York’s five regional airports were down 82 percent “I wish I could go back in time “Any suggestion of blackmail or The call began with Gary Stein, the second quarter. compared with September 2019, and change that decision,” Mr. any other connection to Epstein’s the firm’s head of investor rela- Shares of Apollo were down 2.65 according to data from the Port Black said in prepared remarks reprehensible conduct is categor- tions, reiterating that the firm had percent on Thursday. The stock Authority of New York and New during an earnings call for his ically untrue,” Mr. Black said. never done business with Mr. Ep- has fallen nearly 19 percent since Jersey. TARIRO MZEZEWA firm, Apollo Global Management. Mr. Black said he had given Mr. stein and saying Apollo would not the Times report on Oct. 12. The statement was the latest at- Epstein a second chance after his address the matter beyond Mr. 2008 case because many others in LUCY NICHOLSON/REUTERS tempt by Mr. Black to quell client Black’s remarks. UNITED STATES BANKRUPTCY COURT (the“ SaleOrder ”)is5:00p.m.EasternTimeonDecember10,2020(the Leon Black, the chief of Apollo worries after The New York the world of business, politics and Apollo reported net income of SOUTHERN DISTRICT OF NEW YORK “ Sale Objection Deadline ”).The Auction for the Purchased Assets,if academia had continued to associ- Global Management, in 2018. In re: ) CHAPTER 11 oneisnecessary,willcommenceat10:00a.m.EasternTimeonDecember Times revealed that he had made $272.4 million for the third quar- K.G.IM,LLC, et al ., 1 ) CASE NO.20-11723 (MG) 11, 2020, or such other date as determined by the United States at least $50 million in payments ate with him or retain his services. ter, or $1.11 a share, down from Debtors. ) (Jointly Administered) Bankruptcy Court for the Southern District of New York (the“ Court ”), That had given Mr. Black “mis- NOTICE OF AUCTION AND SALE HEARING at the offices of Alston & Bird LLP,90 Park Avenue,New York,New York and charitable contributions to nature a private person,” deliv- $363.3 million, or $1.63 a share, a 10016,or such other location,including by virtual meeting,as shall be placed comfort,” he said. PLEASETAKENOTICEOFTHEFOLLOWING: timelycommunicatedtoallentitiesentitledtoattendtheAuction. entities associated with Mr. Ep- ered his remarks in a call with an- year earlier. Distributable earn- 1. The above-captioned debtors and debtors in possession 7. A hearing (the“ Sale Hearing ”) to consider the proposed Sale (collectively, the “ Debtors ”) each filed a voluntary petition for relief stein over the past decade. “Like many other people I re- alysts. Normally, Mr. Black stays ings, a closely watched meas- willbeheldbeforetheHonorableMartinGlennoftheCourtat3:00p.m. spected, I decided to give Epstein underchapter11oftheUnitedStatesCode(the“ BankruptcyCode ”)in EasternTimeonDecember16,2020,orsuchotherdateasdeterminedby “Knowing all that I have on such calls to answer questions, urement of the firm’s ability to re- theUnitedStatesBankruptcyCourtfortheSouthernDistrictofNewYork theCourt,atOneBowlingGreen,NewYork,NewYork10004. a second chance,” he said. “This (the“ BankruptcyCourt ”)onJuly28,2020(the“ PetitionDate ”). learned in the past two years but on Thursday he turned mat- turn cash to investors, was $272.4 2. On October 12, 2020, in connection with the proposed sale FilingObjectionstotheSale about Epstein’s reprehensible and was a terrible mistake. I wish I (the“ Sale ”) of the Purchased Assets 2 to BSP Agency LLC, or any other 8. Any objection to the Motion as it relates to the Sale must: (a) Successful Bidder for the Purchased Assets at an auction for the be in writing; (b) state with specificity the nature of such objection; despicable conduct, I deeply re- could go back in time and change Purchased Assets (the “ Auction ”), the Debtors filed a motion (the (c) comply with the Bankruptcy Rules and the Local Bankruptcy Rules gret having had any involvement that decision, but I cannot.” “ Motion ”) [Docket No. 211] seeking, among other things, the entry for the Southern District of New York; and (d) be filed with this Court of an order approving:(a) bidding procedures governing the Sale (the and served upon, so as to be actually received on or prior to the with him,” he said. At the request of Mr. Black, who “ Bidding Procedures ”);(b) the Stalking Horse APA;(c) payment of a Sale Objection Deadline, the following parties: (i) Debtors, Mackinac is Apollo’s chief executive and Break-Up Fee and Reimbursable Expenses to the Stalking Horse Bidder Partners, LLC, 74 W Long Lake Road, Suite 205, Bloomfield Hills, MI Mr. Black, who is also the chair- in certain instances, including if the Successful Bidder at the Auction 48304,Attn:Craig M.Boucher;(ii) counsel to Debtors,Alston & Bird LLP, man of the Museum of Modern chairman, the firm’s independent consummates a transaction, and other bid protections (the “ Bid 90 Park Avenue,New York,New York 10016,Attn:Gerard S.Catalanello Protections ”); (d) procedures for the assumption and assignment andWilliamHao;(iii)CounseltotheDebtors’PrepetitionLenderandDIP Art, said he had paid Mr. Epstein board members have already of executory contracts and unexpired leases (the “ Assumption Lender and Stalking Horse Bidder, Goodwin Procter LLP,The New York for advice on personal financial hired the law firm Dechert to in- Procedures ”); and(e)theformandmannerofnotices. Times Building,620 Eighth Avenue,New York,NY 10018,Attn:Michael 3. On October 23, 2020 the Bankruptcy Court entered an order H Goldstein and Howard S.Steel;(iv) Office of the United StatesTrustee matters, including the structuring vestigate his dealings with Mr. (the “ Bidding Procedures Order ,” Docket No. 260) granting certain Southern District of New York U.S. Federal Office Building, 201 Varick of “art entities” associated with Epstein. The review is expected to of the relief sought in the Motion, including, among other things, Street,Room 1006 NewYork,NewYork 10014 Attn: Shannon Scott and approving:(a) the Bid Protections and the Bidding Procedures and (b) OfficeoftheUnitedStatesAttorneyfortheSouthernDistrictofNewYork his vast collection, which is valued take several weeks to complete. COMMERCIAL & theAssumptionProcedures. 86ChambersStreet,3rdFloorNewYork,NewYork10007. at more than $1 billion. Many big pensions and the con- 4. The Bidding Procedures set forth in detail the requirements for Dated:October30,2020 INDUSTRIAL INVESTMENT submittingaQualifiedBid,andanypersoninterestedinmakinganoffer ALSTON&BIRDLLP, By: /s/GerardS.Catalanello ,GerardS.Catalanello, Mr. Epstein’s advice, which Mr. sultants who advise them about PROPERTIES topurchasethePurchasedAssets must complystrictlywiththeBidding WilliamHao,90ParkAvenue,NewYork,NY10016,Telephone:(212)210- PROPERTIES Procedures. OnlyQualifiedBidswillbeconsideredbytheDebtors . 9400,Email: [email protected],[email protected], Black said had cost him “millions where to invest their dollars are (300) (600) Any persons interested in making an offer to purchase the Purchased CounseltotheDebtorsandDebtorsinPossession of dollars annually,” was vetted by waiting for the results of the inqui- Assets should contact: (i) investment banker to Debtors, Configure 1 The Debtors in these chapter 11 cases,along with the last four digits Professional Offices Pennsylvania 378 Partners, LLC, 3340 Peachtree Road, NE, Atlanta, GA 30326, Attn: Vin of each Debtor’s federal tax identification number (if any),include:K.G. leading lawyers and accountants, ry. At least one client, a public pen- Batra,(678) 723-4575 and (ii) counsel to Debtors,Alston & Bird LLP,90 Brooklyn 183 Restaurant Investment Properties IM,LLC(8556);IlMulinoUSA,LLC(1682);IMLLC–III(2613);IMNYLV,LLC he said. “There has never been an sion fund for Pennsylvania teach- Other Areas 605 Park Avenue,NewYork,NewYork 10016,Attn:Gerard S.Catalanello and (9805);IM NY,Florida,LLC (9385);IM NY,Puerto Rico,LLC (0901);IMNY ers, has already said it will not in- WilliamHao,(212)210-9400. AC,LLC(5082);IMProducts,LLC(0303);IMLongIslandRestaurantGroup, allegation by anyone that I en- Bensonhurst, 80th St, 19th Ave, 5 exam 5. Copies of the Bidding Procedures Order,the Bidding Procedures LLC(1623);IMLongIsland,LLC(1488);IMFranchise,LLC(0565);IM60th gaged in any wrongdoing, be- vest more money with Apollo until rooms with sinks, waiting room, recep- and any other related documents are available upon request to Omni Street Holdings,LLC (9997);IM Broadway,LLC (4335);IMNY Hamptons, tion area, 2 bathrooms, approximately Same family since 1966 Look at Agent Solutions, the Debtors’ notice and claims agent, at (818)-906- www.applevalleyrestaurant.com for LLC (0423) and IM Payroll,LLC (0807). For the purpose of these chapter cause I did not,” Mr. Black said. the investigation is over. 2000 sq ft, $2,300.00 no fee 718-438-4422 FOR SALE BY OWNER - RV park in 8300, or by visiting the case website at https://omniagentsolutions. 11 cases,the service address for the Debtors is:1761Yardley Langhorne pictures and info. 7 + acres, two ponds, Okeechobee, FL - 51 spaces + 1 small com/ilmulino Although Mr. Epstein had been Mr. Black, who said he was “by seven rental/shops, 5000 sq ft restau- Rd.,Yardley,PA19067. newly renovated cottage, $850,000. ImportantDatesandDeadlines 2 Bensonhurst, 80th St / 19th Ave, 5 exam rant, 140 ppl pus bar and outside dining. Call 863-763-7164. Capitalized terms used but not otherwise defined herein have the rooms with sinks, waiting room, recep- 1.8 av yearly sales asking 2.2 million. 6. The deadline to submit a Qualified Bid is 5:00 p.m. Eastern meanings ascribed to them in the Motion or Bidding Procedures, as tion area, 2 bathrooms, approx 2,000 sq right on the Tri-state border, 1.5 hrs Time on December 9, 2020. The deadline to file an objection with applicable. ft $3,000.00 no fee 718-438-4422 from NYC Steve Metzger the Bankruptcy Court to the entry of an order approving the sale