Counsel to REMIC mortgage lender to Daytona Beach hotel project that filed chapter 11 with 78 affiliated entities and was jointly administered under the lead case of Bray & Gillespie Management LLC, case No. 08-05473, in the Middle District of Florida. On behalf of the lender, we sought relief from the automatic stay and opposed the debtors' efforts to substantively consolidate their operations. Our team took the pivotal deposition of the debtors' CFO, which disclosed critical information supporting multiple mortgagees' efforts to oppose the debtors' motion for substantive consolidation. On the eve of the motion for stay relief hearing, the debtors effectively agreed to resolve the stay relief motion by providing for the turnover to the lender of the hotel project pursuant to a plan of reorganization, thereby allowing the transfer to take place without incurring applicable transfer taxes.