NOTICE OF

PUBLIC

AUCTION OF REAL

PROPERTY IN: ALLEGHENY

COUNTY, BEAVER COUNTY,

CLEARFIELD COUNTY,

JEFFERSON COUNTY,

McKEAN COUNTY AND

WESTMORELAND COUNTY, PENNSYLVANIA

MICHAEL F. FLANAGAN, in his capacity as the Court-appointed receiver in Case No. 3:24-cv-52 pending in the United States District Court for the Western District of Pennsylvania (the “Receiver”), hereby posts, pursuant to 28 U.S.C. § 2002, this notice of his intention to sell to the highest qualified bidder the following real and personal property located at the following six (6) locations:

1.IN ALLEGHENY COUNTY: the currently closed facility formerly known as “Jefferson Hills Healthcare and Rehabilitation Center” located at 448 Old Clairton Road, Jefferson Hills, PA 15025, being Parcel No. 767-A-50-0-1 of the City of Clairton, County of Allegheny. This property is being sold for future development without any assurance as to development potential.

2. IN BEAVER COUNTY: the 67-bed licensed nursing facility known as “Beaver Healthcare and Rehabilitation Center” located in the City of Aliquippa at 616 Golf Course Road, Aliquippa, PA 15001, being Parcel No. 65-006-7313.001 of the City of Aliquippa, County of Beaver.

3. IN CLEARFIELD COUNTY: the 131-bed licensed nursing facility and the related continuing care retirement community known as “Ridgeview Healthcare and Rehabilitation Center” located in the City of Curwensville at 30 4th Street, Curwensville, PA 16833, being Parcel No. H09-691-00014 in the City of Curwensville, County of Clearfield.

4. IN JEFFERSON COUNTY: the 75-bed licensed nursing facility and related continuing care retirement community known as “Mulberry Healthcare and Rehabilitation Center” located in the City of Punxsutawney at 411-1/2 West Mahoning Street, Punxsutawney, PA 15767, being Parcel Nos. 24-002-0411, 24-002-0428, 24-002-0427, 24-002-0408A, 24-002-0425A, 24-002-0426, 24-002-0408B, 24-002-0422 and 24-002-0425 in the Borough of Punxsutawney, County of Jefferson.

5. IN McKEAN COUNTY: the 34-bed licensed nursing facility and related 28-bed licensed personal care home known respectively as “Lakeview Healthcare and Rehab “and “Lakeview Senior Care” located in the City of Smethport at: 15 West Willow Street, Smethport, PA 16749, being Parcel Nos. 15-005-607 and 15-005-605.01 of the City of Smethport, County of McKean.

6. IN WESTMORELAND COUNTY: the 35-bed licensed nursing facility known as “Scottdale Healthcare & Rehabilitation Center” located in the City of Scottdale at 900 Porter Avenue, Scottdale, PA 15683, being Parcel No. 47-13-12-0-015, 47-13-12-0-014 and 47-13-12-0-013 of the City of Scottdale, County of Westmoreland.

The Receiver is prepared to enter into a stalking horse contract with affiliates of 980 Investments and Heart Healthcare Management LLC. That contract provides for a refund of the deposit and specifies the starting minimum bid that will be required. The stalking horse contract includes a Purchase Price of $37,418,377.48 subject to a $9,224.22 per diem adjustment (positive or negative) to the extent that the Closing does not occur on September 3, 2025, plus all closing costs to be paid by the Buyer, with the Buyer depositing with its Title Company the cash sum of $1,000,000.00 (One Million Dollars to be applied at closing as a cash payment against the Purchase Price with the remainder paid by assumption of the remaining balance of the existing mortgage lien against properties subject to underwriting clearance by the current mortgage holder.

Any competing offers for the entire package must be made pursuant to the terms and conditions set forth in the Sales Procedures approved by the Court, must offer a purchase price of at least $37,669,000.00, and should be received in good form no later than six (6) business days prior to the date scheduled for public auction.

The properties will be sold at public auction, unless there are no other Qualifying Bids, such auction to be held on Wednesday, September 3, 2025 at 9:00 AM (Eastern Time then prevailing) in person at the Law Office of Cozen O’Connor, One Oxford Centre, 301 Grant Street (41st Floor), Pittsburgh, PA 15219, although the Receiver may determine in his discretion to provide a ZOOM link for additional participants with the link to be provided in advance by the Receiver to all Qualified Bidders. Sales will be for cash or cash equivalents. The Sales Procedures require bidders to post a deposit in cash or certified funds of One Million Dollars ($1,000,000.00). Sales will be “AS IS” with no representations or warranties of any type, other than those contained in the Asset Purchase Agreement negotiated with Stalking Horse and will close upon receipt of required regulatory approvals.

The Receiver reserves the right to postpone or adjourn the auction, to accept any bid or to reject any and all bids that he does not believe to be in the best interests of the receivership estate, or to withdraw the properties at any time prior to the announcement of the completion of the auction. The Receiver’s acceptance of any bid is expressly conditioned on the successful bidder executing a purchase and sale agreement in form and content satisfactory to the Receiver, in consultation with Plaintiff (the current mortgage holder) and complying with the Sales Procedures.

For additional information, including legal descriptions of the properties, a copy of the Sales Procedures, or to make a competing offer for the properties, please contact (email):

• Louis J. Capozzi, Jr., Esq. and Daniel K. Natirboff, Esq., Capozzi Adler, P.C., 2933 North Front Street, Harrisburg, PA 17110-1250, EMAIL: dann@capozziadler.com – counsel to the Receiver

• Michael F. Flanagan, Receiver, 7611 State Line Road (Suite 303), Kansas City, MO 64114, EMAIL: MikeFlanagan@mffllc.com – Receiver

• Eugene A. Giotto, Esquire, Cozen O’Connor, P.C., One Oxford Centre (41st floor), 301 Grant Street, Pittsburgh, PA 15219 ) (Email: egiotto@cozen.com), counsel for Plaintiff