27. Debtor furnished no consideration for the purchase of any of the IAS Properties and never intended to acquire or retain legal title or ownership to any of the IAS Properties, except for the convenience of IAS in obtaining one or more loans for the purchase of the IAS Properties, the IAS Properties being purchased by IAS for the purpose of constructing Solar Power Generation facilities and being used solely for that purpose to date. See photos of the IAS Properties attached as Exhibit “S”.
28. Neither of the IAS Deeds issued by Debtor constituted a fraudulent conveyance under the Utah Fraudulent Conveyance Act or any other law, and the IAS Deeds included in Exhibit I and Exhibit R, transferred legal title to the intended and actual purchaser of the IAS Properties, namely IAS.