In re: Necole Marie Kucinski and Bridger Gene Kucinski

United States Bankruptcy Court, D. Colorado·Decided July 27, 2026·No. 26-11428·Unknown

Opinion

In re:

NECOLE MARIE KUCINSKI and Case No. 26-11428 KHT BRIDGER GENE KUCINSKI, Chapter 11

Debtors.

ORDER ON MOTIONS FOR RELIEF FROM STAY

THIS MATTER came before the Court on the Motion for Relief from the Automatic Stay (2509 Ehrich Street, Colorado Springs, CO 80904) (docket #54) and the Motion for Relief From the Automatic Stay (1001 Race Street and 1003 Race Street) (docket #77) (collectively, the “Motions”), filed by Integrity Bank & Trust (the “Bank”), and the Objection to Integrity Bank & Trust’s Motion for Relief from Stay (2509 Ehrich Street) (docket #81) and Objection to Integrity Bank & Trust’s Motion for Relief from Stay (1001 and 1003 Race Street) (docket #100) (collectively, the “Objections”), filed by the Debtors, Necole and Bridger Kucinski (“Debtors”). The Court held an evidentiary hearing on the Motions on June 15 and 16, 2026, following which the matter was taken under advisement. The Court is now prepared to rule and hereby finds and concludes as follows:

I. JURISDICTION

This Court has jurisdiction over this matter under 28 § 1334(a) and 28 U.S.C. § 157(a) and (b)(1). This is a core proceeding under 28 U.S.C. § 157(b)(2)(A) and (G), as it involves administration of the bankruptcy estate and involves a motion to terminate, annul, or modify the automatic stay.

II. STIPULATED FACTS

The parties stipulated to the following facts:

A. Construction Loan.

1. On December 2, 2020, pursuant to that certain Construction Loan Agreement (the “CLA”), the Bank made a loan of money to Go Freedom Nation Investment Group, LLC (“GFN”), an entity owned exclusively by the Debtors, in the principal amount of $448,443.00 (the “Construction Loan”).

2. In furtherance of the Construction Loan, GFN made, executed and delivered its promissory note to the Bank in the principal amount of $448,443.00 (the “Construction Loan Note”).

3. To secure the obligations under the CLA and Note, GFN executed that certain Construction Deed of Trust dated December 2, 2020 (the “Construction Loan DOT”) which granted a first position security interest against 2509 Ehrich Street, Colorado Springs, CO Colorado, on December 8, 2020, at Reception No. 220199304. 4. As an inducement to making the Construction Loan, on December 2, 2020, the Debtors and Go Freedom Ventures dba K2 Homes each gave their absolute and unconditional guarantee of GFN’s obligations under the CLA and Note (the “Construction Loan Guarantees”).

5. The Construction Loan Note has been modified from time to time, by execution of Change in Terms Agreements (collectively, the “Construction CITs”), as provided for below:

Execution Date Description of Principal Change in Terms December 6, 2021 Extension of maturity date to March 1, 2022 March 14, 2022 Extension of maturity date to June 1, 2022 June 29, 2022 Extension of maturity date to December 1, 2022 December 20, 2022 Extension of maturity date to June 1, 2023 June 12, 2023 Extension of maturity date to December 1, 2023 and increase the principal balance of the Construction Loan to $523,433.00 November 6, 2023 Extension of maturity date to January 1, 2024 February 6, 2024 Extension of maturity date to February 28, 2024, and increase the principal balance of the Construction Loan to $549,685.00 April 24, 2024 Extension of maturity date to November 1, 2024, and increase the principal balance of the Construction Loan to $610,309.27 December 23, 2024 Extension of maturity date to December 1, 2027 January 13, 2025 Change monthly payments from due on the 1st to the 20th

6. The Construction DOT has been modified from time to time, by execution of Modification of Deeds of Trust (the “Construction DOT Modifications”), as provided for below:

Recording Date Recording Number Description of Modification November 13, 2023 223093766 Increase of principal balance of the Construction Loan to $523,433.00 February 9, 2024 224009585 Increase of principal balance of the Construction Loan to $549,685.00 April 25, 2024 224030633 Increase of principal balance of the Construction Loan to $610,309.27

7. In order to further secure the Construction Loan, GFN executed that certain Assignment of Rents (“Construction AOR”) dated April 24, 2024, that was recorded with the Clerk and Recorder of El Paso County, Colorado, at Reception No. 224030634. 8. On September 28, 2022, pursuant to that certain Business Loan Agreement (the “BLA”), the Bank issued a line of credit (the “Line of Credit”) to the Debtors, jointly and severally, in the principal amount of $152,000.00.

9. In furtherance of the Line of Credit, the Debtors made, executed and delivered their promissory note to the Bank in the principal amount of $152,000.00 (the “LOC Note”).

10. To secure the obligations under the BLA and LOC Note, GFN executed that certain Deed of Trust dated September 28, 2022 (the “LOC DOT”) which granted a second position security interest against Lot 20 and was recorded with the Clerk and Recorder of El Paso County, Colorado, on September 30, 2022, at Reception No. 22125764.

11. The LOC DOT also granted a first position security interest against 1001 Race Street, Colorado Springs, CO 80904 (“1001 Race”), and 1003 Race Street, Colorado Springs, CO 80904 (“1003 Race”).

12. The LOC DOT also granted a third position security interest against 90 Polo Pony Drive, Colorado Springs, 80904.

13. As an inducement to making the LOC, on September 28, 2022, Go Freedom Nation Investment Group Ltd., and Go Freedom Ventures, LLC, each gave their absolute and unconditional guarantee of Debtors’ obligations under the BLA and LOC Note (the “LOC Guarantees”).

14. The Line of Credit has been modified from time to time, by execution of Change in Terms Agreements (collectively, the “LOC CITs”), as provided for below:

Execution Date Description of Principal Change in Terms December 20, 2022 Extension of maturity date to June 1, 2023 March 13, 2023 Increase principal balance of Line of Credit to $200,000.00 November 6, 2023 Extension of maturity date to January 31, 2024 February 6, 2024 Extension of maturity date to February 28, 2024 April 24, 2024 Extension of maturity date to November 1, 2024 and increase principal balance of Line of Credit to $222,937.13 December 23, 2024 Extension of maturity date to December 1, 2027 January 13, 2025 Change monthly payments from due on the 1st to the 20th

15. The LOC DOT has been modified from time to time, by execution of Modification of Deeds of Trust (the “LOC DOT Modifications”), as provided for below:

Recording Date Recording Number Description of Modification March 16, 2023 223021313 Increase of principal balance of the Line of Credit to $200,000.00 April 25, 2024 224030827 Increase of principal balance of the C. Encumbrances Against Lot 20.

16. On February 9, 2024, Mar Mar Inc. d/b/a Meyer Electric recorded a Statement of Lien against Lot 20 for unpaid labor or materials, in the amount of $14,581.00, with the Clerk and Recorder of El Paso County, Colorado at Reception No. 224009509 (the “Mechanics Lien”).

17. On March 27, 2024, Debtor Necole Kucinski caused GFN to execute and record that certain Quitclaim Deed with the Clerk and Recorder of El Paso County, Colorado, at Reception No. 224016555 which purported to transfer Lot 20 from GFN to Necole.

18.

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In re: Necole Marie Kucinski and Bridger Gene Kucinski, (Colo. 2026).

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