Evgeny Orlov this morning said that he yesterday received an application, from legal representatives for Rabobank, to either have the cats removed from the park or put down.
The application is to be heard in the High Court at Whangarei on Wednesday.
He said Patricia Busch, the garden's owner, was "deeply distressed" at the idea the cats may be killed.
"It seems illogical to kill 36 beautiful cats when there could be other solutions."
The park was placed into liquidation in August last year after the High Court in Whangarei ruled that it could not pay its debts, believed to be up to $100,000.
Orlov, who has been working on the case pro bono for about five months, said that a hearing had been set down for February in the High Court and it was at that stage that the animal's future was to be decided.
He said the late application had left he and his client Patricia Busch, the owner of the garden's, very little time to prepare.
Orlov said he hoped to be able to stop the application. "We will be doing our best".
Orlov said Busch has always maintained that she had no problem with receivers taking over the park as long as she could continue to look after the animals.
Busch has remained at the park caring for the animals with the assistance of local farmers, who have supplied meat, and from the bank.
He said the court only allowed the receivers in on the condition that Busch stay.
"Our argument was that under the international convention that they cannot trade, and therefore cannot have security over, the animals . . .[The hearing in February] would have decided a very interesting question of law. Which is whether wildlife can be owned at all, and whether it can be traded.
"In the same way that you cannot own a child, but you can look after a child until it reaches maturity, the same way with wildlife we were arguing that you can't own it."
Orlov said he had been having discussions both overseas and within New Zealand about the future of the cats but that while the issue of ownership remained no agreements could be made.
"No one can have serious discussions without proof the animals are owned."
A legal representative from Rabobank confirmed that a hearing is being held in the High Court on Wednesday, but declined to comment further.