Citing commercial sensitivity, Justice Mark Woolford allowed only lawyers to see an abridged version of the document - with names and figures left out.
Mr Orlov took exception to that, saying it was a "gagging'' tactic.
But Justice Woolford said it was normal practice to allow confidentiality in such matters, especially given the sale had not been completed.
The sale of the park would not include its big cats, which include lions, cheetah and white tigers, and there will be another hearing in Whangarei next month about their ownership.
Mr Orlov told the court the receivers had been interfering with the cats' care and said the animals were "suffering'' as a result.
He had anticipated today's hearing would be about whether they could be put down, and said PWC lawyer Mr Toebes had tried to avoid the issue due to the large media presence in court.
Mr Toebes said this was not the case and he was merely going through the normal process of ending a receivership.
"It's simply to enable the receivers to retire, nothing else.''
Mr Orlov later accepted this was the case.
The International Fund for Animal Welfare today joined calls to rehouse rather than euthanise the big cats, but Rabobank New Zealand, who called in the receivers, denied they would be killed.
"There is not, and has never been, any intention to euthanise any animals at Zion Wildlife Gardens,'' said general manager Ben Russell.
"The welfare of the wildlife is a priority - they are being very well cared for and the planned sale of the park would enable them to remain in place.''
Mr Toebes also made an application regarding the receivers' access to the park. That was adjourned until next week with lawyers indicating it may be resolved outside court.
The park was opened in 2002 by Craig Busch, star of television show Lion Man.
It was taken over by his mother Patricia in 2006 after she raised money to pay off the park's debts.
A protracted legal battle between the pair ensued, with Mr Busch leaving the park in 2008.
The zoo's troubles have been long-running and include the death of South African keeper Dalu Mncube, who was mauled by an endangered white tiger in 2009. The cat was put down.