5. According to the Pro Mold, Inc. Disbursement Journals that are attached hereto and incorporated herein as Exhibit “1”, “2” and “3”, Debtor Pro Mold has transferred the following amounts to Debtor Plasticon since June 22, 2007 for management fees:
Date Amount
a. June 22, 2007 $ 7,500.00
b. June 29, 2007 $ 7,500.00
b. July 6, 2007 $ 7,500.00
c. July 10, 2007 $ 7,500.00
Total $30,000.00
6. According to counsel for Debtor Pro Mold and Debtor Plasticon, Debtor Plasticon directed Debtor Pro Mold to pay these management fees to Debtor Plasticon “out of necessity because Debtor Plasticon had no money to pay its’ payroll.”
7. If Debtor Plasticon has no money to pay its’ payroll, Debtor Plasticon has no money to pay a $25,000 retainer to the attorney for the Official Committee of Unsecured Creditors.
8. James Turek, Sr. reported to the Court on or about May 22, 2007 that Debtor Pro Mold had a written management agreement with Debtor Plasticon that provided for Debtor Pro Mold to pay Debtor Plasticon $25,000 per month.
9. The Court instructed Debtor Pro Mold to produce a copy of the written management agreement.
10. As of this date, no written management agreement has been produced.
From:
07/20/2007 122 Objection Filed by Pro Plas LLC (RE: related document(s)102 Application to Employ). (Attachments: # 1 Continuation of Main Document) (Case, E.) (Entered: 07/20/2007)
--------------------
Doc 122 pages 1 to 5
SEE -
Message 23720468 |
