a. James Turek testified during his deposition in this case that an agreement was reached with George Butler, Chief Executive Officer of FNBB in Las Vegas, Nevada reducing the indebtedness from $1,448,039.95 to $500,000 and that the agreement was recorded on a cocktail napkin.
b. Attached hereto and incorporated herein as Exhibit "A" is a cocktail napkin from the Rio All Suites Hotel & Casino in Las Vegas, Nevada that has written on it "Agreement between Plasticon & First Nat'L Barnesville" and is executed by "James Turek Pres, Plasticon" and by "George Butler, CEO. FNBBV".
c. Attached hereto and incorporated herein as Exhibit "B" is a copy of a letter dated February 22, 2005 from George Butler, President of FNBB, addressed to "Jim" in regard to FNBB selling "Wicklund Holding Company's original loan to Promotional Container, Inc." and terminating FNBB's "previous agreement with Wicklund Holding Company".
d. In the February 22, 2005 letter George Butler stated "As I have indicated to you I have released the collateral and will shortly provide you the loan documents and pay-off statements per our agreement."
e. Attached hereto and incorporated herein as Exhibit "C" is a copy of a letter dated April 21, 2006 from "George" at FNBB addressed to "Jim" verifying that "as of January 1, 2005 your company's (Plasticon's) debt to our bank was $500,000." and a copy of the FNBB fax coversheet dated April 21, 2006 from George Butler to Judy Payner at Plasticon.
04/16/2008 432 Objection Filed by 10315 LLC, John P Murphy III, John P. Murphy Revocable Trust No. 1 III, Pro Plas LLC (RE: related document(s)407 Motion for Relief From Stay filed by Creditor First National Bank of Barnesville, Georgia). (Case, E.) (Entered: 04/16/2008) |