I hereby verify that all of the information contained in this First Amended Disclosure Statement is true and correct to the best of my knowledge and belief.
/s/ C. Edwin Rude, Jr., Esquire
C. EDWIN RUDE, JR., ESQUIRE
02/23/2005 285 Third Amended Disclosure Statement Filed by Debtor JAMES N. TUREK (RE: related document(s)129 Disclosure Statement). (Attachments: # 1 Composite Exhibit A)(Rude, C.) (Entered: 02/23/2005)
UNITED STATES BANKRUPTCY COURT
NORTHERN DISTRICT OF FLORIDA
PANAMA CITY DIVISION
IN RE:
JAMES N. TUREK, CASE NO. 02-20411-PCY5
CHAPTER 11
Debtor.
THIRD AMENDED DISCLOSURE STATEMENT
I. INTRODUCTION
JAMES N. TUREK (“Turek” or "Debtor") provides this Disclosure Statement (the "Disclosure Statement") to all known creditors of the Debtor in order to disclose the information deemed to be material, important, and necessary for the creditors to arrive at a reasonably informed decision in exercising their right to vote for acceptance or rejection of the Plan of Reorganization (hereinafter "the Plan").
The Bankruptcy Court has set a hearing on this Third Amended Disclosure Statement and on confirmation of the Third Amended Plan of Reorganization as restated for March 25, 2005 at 9:00 a.m. C.S.T.at the U. S. Courthouse, 30 W. Government St., Panama City, Florida. Creditors may vote on the Plan if their claim is impaired by filling out and mailing the accompanying ballot form to the Bankruptcy Court. Some classes of creditors are impaired and a separate ballot for the use of said classes of creditors in indicating their acceptance or rejection of the Plan is enclosed with this Disclosure Statement. As a creditor, your vote is important. In order for the Plan to be deemed accepted, of the ballots cast, creditors that hold at least two-thirds in dollar amount and more than one-half in number of the allowed claims of impaired classes must vote to accept the Plan. However, you are advised that the Debtor may be afforded the right under the Bankruptcy Code to have the Plan confirmed over the objections of dissenting creditors consistent with the limitations set forth in the Bankruptcy Code.
NO REPRESENTATIONS CONCERNING THE DEBTOR ARE AUTHORIZED OTHER THAN AS SET FORTH IN THIS STATEMENT. ANY REPRESENTATIONS OR INDUCEMENTS MADE TO SECURE YOUR ACCEPTANCE WHICH ARE OTHER THAN AS CONTAINED IN THIS STATEMENT SHOULD NOT BE RELIED UPON BY YOU IN ARRIVING AT YOUR DECISION AND SUCH ADDITIONAL REPRESENTATIONS AND INDUCEMENTS SHOULD BE REPORTED TO COUNSEL FOR DEBTORS WHO IN TURN SHALL DELIVER SUCH INFORMATION TO THE UNITED STATES TRUSTEE FOR SUCH ACTION AS MAY BE DEEMED APPROPRIATE.
Debtor filed a voluntary petition for reorganization under Chapter 11 of the United States Bankruptcy Code, 11 U.S.C. 101 et seq. (the "Bankruptcy Code") in the United States Bankruptcy Court for the Northern District of Florida (the "Bankruptcy Court") on May 14, 2002.
The Debtor has continued to manage Wicklund Holding Company (WLC) and became Managing Partner of Show Me Ink, LLC, a Nevada corporation in March, 2003. You are urged to carefully read the contents of this Disclosure Statement before making your decision to accept or reject the Plan. Particular attention should be directed to the provisions of the Plan affecting or impairing your rights as they presently exist. The terms used herein have the same meaning as in the Plan unless the context hereof requires otherwise.
THE INFORMATION CONTAINED IN THIS DISCLOSURE STATEMENT HAS BEEN SUBMITTED BY THE DEBTOR, UNLESS SPECIFICALLY STATED TO BE FROM OTHER SOURCES. NO REPRESENTATIONS, OTHER THAN THOSE SET FORTH HEREIN, CONCERNING THE DEBTOR ARE AUTHORIZED BY THE DEBTOR. IF THE PLAN IS CONFIRMED, YOU WILL BE BOUND BY ITS TERMS. THEREFORE YOU SHOULD MAKE SUCH INQUIRIES YOU DEEM NECESSARY AND APPROPRIATE AND THEN CA ST YOUR VOTE ON THE PLAN.
Under the Plan, the claims of Creditors, depending upon classification of their respective claims (see Plan of Reorganization) will either (a) be paid in full, (b) be paid in part or not at all based on the Court’s ruling on any Objection to Claim filed, or (c) survive the Debtor’s Reorganization unimpaired.
II. HISTORY OF THE DEBTOR AND REASONS FOR FILING PETITION
International Plastic Corporation, Inc. (IPC) was a privately held Kentucky corporation formed by Debtor in 1988 and Wicklund Holding Company (WHC) is a Delaware corporation created by the Wicklund family and went public in 1981. In June 1997, WHC, although a nonreporting NASDAQ shell name, was dormant, merged into IPC and the Wicklund name was retained. As a result of this merger, IPC’s shareholders ended up with 80% of the shell stock as IPC had assets valued by appraisal at nearly $15,000.000.00 (molds and patents). At the time, IPC had 124 shareholders and Wicklund had approximately 800 shareholders. After the merger, Wicklund issued approximately 5.6 million of its 20 million shares of Treasury Stock. On June 30, 1997, WHC looked to acquire or merge with other companies, as it only required sales and SEC approved audits to again be trading on NASDAQ and initiated negotiations in 1998 for the acquisition of Florida Curbing, Inc. (FC) and Laser Engineering, Inc. (LE) (sister companies with same owners) and acquired these companies in 1998. The acquisition occurred through a reverse triangle “A” merger in which a company is created to put the acquired companies into so that they supposedly cannot carry “baggage” with them into the merger (i.e., back taxes, payables, fraudulent transactions, etc), and in the event that fraud was subsequently discovered. To accomplish this merger Wicklund’s lawyers created Wasalooski Inc., which merged with FC and LE in December 1998, at which time Wasalooski ceased to exist by operation of law with the survivor being Wicklund with FC and LE as its two subsidiaries.
In order to be trading in NASDAQ, WHC was required to have Securities and Exchange Commission (SEC) audits covering three years (2 years prior to the merger, and 1 year after the merger) and initial audits of FC and LE were started in early 1999. WHC with its assets arranged for funding against FC & LE receivables. During the period December 1998 through Wicklund’s recission of the merger in November of 2000, at various times, Town Finance, Wicklund, through First National Bank of Barnesville, Emerald Coast Bank and Export Finance Network served as factors for FC & LE receivables.
Upon the initiation of the audits, LE’s CFO disappeared. The auditors told WHC and Debtor that LE and FC were not auditable as their books were loaded with fraud (un-reported receivables and receivables reported current that in some case were 6 months old), just to start. FC had the same problems as LE but much worse and included fraud related to a clandestine and fraudulent relationship between the original owner of FC (who remained as its operations officer and president by contract) with an unknown minority contractor and operated out of the offices of FC. Three SEC approved and insured Auditing firms concluded that LE & FC were not auditable. Letters from the various auditing firms are attached as Composite Exhibit “A.”
During this relationship with FC, Debtor’s signature stamp was stolen from his accounting and bookkeeping firm in Florida. Turek’s signature card at Nations Bank/Bank of America was changed without his permission resulting in $1,500,000.00, plus, being drained, WHC and Debtor believe, by the original owner of FC & LE Rudy Poselli. Payroll checks normally signed by him as President of FC were stamped with Debtor’s stamped signature beginning in May of 2000.
WHC and Debtor did file a criminal Complaint in Broward County, Florida in June 2000, which is still pending. The Broward County Sheriff’s Department also suggested Debtor file a lawsuit as it would help them. Unfortunately, Debtor had used all his means to continue moving forward and subsequently filed to reorganize under Chapter 11. As a result of this fraud, Debtor lost valuable real property in Bay County, Florida, as well as his significant equity in his pleasure boat and fishing boat.
Wicklund is now known as Plasticon International, LLC.
III. OBJECTIONS TO CLAIMS AND PREFERENCE ANALYSIS
Pursuant to the Plan, the Debtor may object to any scheduled Claim or Proof of Claim filed against the Debtor. Such an objection shall preclude the consideration of any claims as "allowed" for the purposes of timely distribution in accordance with the Plan. It is the Debtor's position that
at this time there are no preferences or voidable transfers which the Debtor can pursue. Pursuant to the Bankruptcy code, Debtor may file claims for those creditors who did not file claims.
A Claims Bar Date was established of July 24, 2003. The Debtor has not filed objections to claims as of the date of this Disclosure Statement. The Debtor will file any necessary objections to claims of creditors based upon duplicative claims being filed, amended claims being filed or based upon the Debtor's belief that the amount due and owing to the claimant has been miscalculated, is less than claimed or not due and owing at all. Pursuant to the local rules of the Northern District of Florida, Debtor may file objections to claims up to thirty days after confirmation.
IV. SOURCE OF FINANCIAL INFORMATION
The source of financial information for this Disclosure Statement and Plan is the Debtor.
V. DEBTOR'S OPERATION AND STRUCTURE
Synopsis of Operation In Chapter 11
Subsequent to the Petition date, Debtor managed Wicklund, arranging for an agreement for marketing and distribution of “Patch-Aid” a product designed to detect chemicals emitted by the body as a result of over exertion and in so doing, indicating the potential for a stroke or heart failure. Said product is presently being reviewed by the Federal Drug Administration. In March 2003, Debtor became Managing Partner of Show Me Ink, LLC, a Nevada photo products corporation.
VII. STRUCTURE OF REORGANIZED DEBTOR
1. The Reorganized Debtor
As the Debtor is an individual, upon the Effective Date, the Reorganized Debtor shall continue with his management of Wicklund and as Managing Partner of Show Me Ink, LLC .
B. Retention of Assets
Upon the Effective Date, the Reorganized Debtor shall retain his interest in his real and personal property, and shall be free to operate and to perform any and all acts without further order from the Court and title to his assets shall remain vested in Debtor.
VIII. CLAIMANTS AND SUMMARY OF THE PLAN
Claimants entitled to vote under the Plan must affirmatively act in order for the Plan to be confirmed by the Court. According to the Debtor's Plan, a member of Classes are "impaired" within the meaning of Section 1124 of the Bankruptcy Code. These Classes, accordingly, must vote to accept the Plan in order for the Plan to be confirmed without a cram down. A Claimant who fails to vote to either accept or reject the Plan will not be included in the calculation regarding the acceptance or rejection of the Plan.
Although Debtor’s Plan of Reorganization contemplates a One Hundred Percent (100%) payout to its creditors, a ballot for acceptance or rejection of Debtor’s Plan by the holders of Claims and/or Interests which may be impaired is included herewith in the event it becomes necessary for creditors of a class to vote on Debtor’s Plan. Instructions for completing and returning the ballots are be provided in the ballot for the creditor(s) in such class and should be carefully reviewed. The Plan will be confirmed by the Bankruptcy Court and made binding upon all holders of claims and interests, and if it becomes necessary for creditors of a class to vote on Debtor’s Plan, it will be confirmed by the Bankruptcy Court and made binding upon all holders of claims and interest if, with respect to Classes or Claimants determined to be impaired, the Plan is accepted by holders of two-thirds in dollar amount, and more than one-half in number of Claims in each such class voting upon the Plan. In the event the requisite acceptances are not obtained, the Bankruptcy Court may, nevertheless, confirm the Plan if it finds that the Plan accords fair and equitable treatment to any class rejecting it. Your attention is directed to Section 1129 of the Bankruptcy Code for details regarding the circumstances of such provisions.
Summary of the Plan
CREDITORS AND OTHER PARTIES IN INTEREST ARE URGED TO READ AND
REVIEW THE FULL TEXT OF THE PLAN PRIOR TO VOTING ON WHETHER TO OBJECT TO CONFIRMATION OF THE PLAN AND, SHOULD IT BECOME NECESSARY FOR A VOTE ON THE PLAN BY A PARTICULAR CLASS, WHETHER TO ACCEPT OR REJECT THE PLAN.
The claims of creditors are divided into twenty classes or sub-classes. Administrative Claims, including all fees remaining to be paid to the Bankruptcy Court or the U.S. Trustee's Office and professional fees and expenses approximating $75,000.00 will be paid in full, in cash, on the Effective Date, or as agreed to between the parties. The claims of the Class 1 Creditor, Bank One will be paid in full with interest at 7% per annum amortized over a period of ten years with a balloon payment due after five years, the Class 2 Creditor, Central Bank, will be paid in full with interest at the rate of 7% per annum amortized over a period of ten years with a balloon payment due after seven years; the Class 3 Creditor, Community Trust Bank will be paid pursuant to the terms of its contract, payments amortized over a period of seventeen years and any balance due paid in full upon any closing on a sale of the real property securing their debt; the Class 4, Daimer Chrysler, and the Class 7, GMAC claims have been satisfied; the Class 5 creditor, Eastern Savings Bank, will have its Class A claim satisfied by payment in full with interest at 9.99% per annum amortized over a period of twenty - five years and its Class B claim will be satisfied by payment in full together with interest at 8.5% per annum amortized over a period of twenty-five years with a final balloon payment due after five years; the Class 6 creditor, Edgewater Beach Resort Community Association will have its claim satisfied in full with interest at the rate of 7.9% per annum amortized over a period of eighteen months; the Class 8 creditor, Hartland Homeowners Association, will have its claim paid in full ten days after the Effective Date; the Class 9 creditor, Kentucky Bank, shall have its claim satisfied in full with payments pursuant to the current contract rate with adjustments which may be required as a result of this creditors loan index rate; the Class 10 creditor, Kitch Drutchas, will have its secured claim satisfied in full with half of same paid upon the Effective Date and the remaining half, together with interest at 7% per annum, being paid within six months of the Effective Date; the Class 11 A&B creditor, LFUGC-Division of Revenue shall have its claims paid in full together with interest at 7% per annum with payments over a period of five years; the Class 12 creditor, Marlinrob, Inc., shall have its claim paid in full with interest at 7% per annum amortized over a period of fifteen years and any balance due paid in full upon any closing of a sale of the real property which is security for its debt; Class 13 creditor, National City Bank has been satisfied in full pursuant to a Consent Order providing for adequate protection payments; the Class 14 creditor Stoll, Keenon & Park, LLP will be paid in full together with interest at the rate of 4.25% per annum amortized over a period of twenty-five years with a balloon payment at the end of fifteen years and any balance due paid in full upon any closing of a sale of the real property which is security for its debt, with the balance of its claim being unsecured and treated as a Class 18 claim; the Class 15 claim of Bay County Tax Collector will be paid in full within thirty days of the effective date; the Class 16 secured claim of Dennis Joslin will be treated as a Class 20 claim pursuant to a stipulation with Wicklund and debtor; the Class 17 secured claim of Edgewater Beach Resorts Partnership will be satisfied by crediting Debtor with the value of the Wicklund stock held as security as of the effective date, with the balance of its claim treated as a Class 20 unsecured claim; the Class 18 unsecured creditors will be paid in full, with interest at 1½% per annum with payments being amortized over a period of fifteen years with monthly payments over a period of five years and a balloon payment at the end of the five year period. The present value of these creditors claims is approximately 93% of the claims for 5 years and 84.5% as to the balloon. Class 19 administrative class shall have their claims satisfied in full without interest by quarterly payments for one year. The present value of these creditors claims is approximately 99 % of the claims. Class 20 unsecured creditors, will have their claims against Debtor paid in full by transfer of stock with a present value approximating 11 % of their claims being issued by Wicklund Holding Company upon confirmation of Debtor’s Plan, at which time Debtor will be released from liability and Wickland will remain liable for the balance of the joint debt secured by the Wicklund stock until the Wicklund stock is sold, at which time any balance owed by Wicklund will be deemed satisfied and paid in full and the terms of any stipulation between Plasticon and/or debtor with members of this class shall control to the extent inconsistent with the plan.
LIST OF CREDITORS IN EACH CLASS
Class 1: Claim of Bank One Financial Services, Inc.
Class 2: Claim of Central Bank & Trust Co.
Class 3: Claim of Community Trust Bank
Class 4: Claim of DaimlerChrysler Services
Class 5
A-B: Claims of Eastern Savings Bank
Class 6: Claim of Edgewater Beach Resort Community
Class 7: Claim of General Motors Acceptance Corp.
Class 8: Claim of Hartland Homeowners Assoc. Inc.
Class 9: Claim of Kentucky Bank
Class 10: Kitch Drutchas Wagner Denardis & Valitutti ( “Kitch Drutchas”)
Class 11
A-D: Claims of LFUCG-Division of Revenue
Class 12: Claim of MarlinRob, Inc.
Class 13: Claim of National City Bank
Class 14: Claim of Stoll, Keenon & Park, LLP
Class 15: Bay County Tax Collector
Class 16: Claim of Dennis Joslin
Class 17: Claim of Edgewater Beach Resorts Partnership
Class 18: Unsecured Claims of Debtor
Class 19: Unsecured Claims Under $5,000.00
Class 20: Unsecured Claims of Creditors of Wicklund,
its subsidiaries or affiliates and Debtor as Guarantor
IX. IMPLEMENTATION OF THE PLAN
The distributions called for under the Plan to be paid administrative claimants and the initial payments to the Class 16 administrative creditors shall be paid by Debtor’s counsel, with all other payments being made by debtor.
X. LIQUIDATION ANALYSIS
The Debtor believes that its Plan provides the greatest possible return upon the claims of all creditors and is in the best interests of all creditors. As with any plan, an alternative to the successful confirmation of the Debtor's Plan would be the dismissal of the Chapter 11 proceedings or a conversion of the Chapter 11 case to a Chapter 7 case and subsequent liquidation of the Debtor and his assets by a duly appointed Chapter 7 trustee. In the event of a liquidation of the Debtor and his assets under Chapter 7, the following is likely to occur:
(a) An additional tier of administrative expenses, entitled to a greater priority than general unsecured claims, under 11 U.S.C. § 507(a)(1) of the Code would be incurred. Such administrative expenses would include, but would not necessarily be limited to, trustee's commissions and fees to the trustee's accountants, attorneys, and other professionals likely to be retained by the trustee for the purpose of liquidating the assets of the Debtor, together with the costs of preserving the assets of the estate pending liquidation;
(b) The vast majority of Debtor’s assets rest in his stock in Wicklund and the back salary owed him by Wicklund. His back salary, if paid, is exempt and the condominium in Bay County and the rental property in Lexington, Kentucky, are exempt from unsecured creditors due to their being owned jointly by Debtor and his wife.
(c) Further claims would be asserted against the Debtor estate with respect to such matters as income and other taxes associated with the sale of assets, and the inability of the Debtor to fulfill his outstanding responsibilities to Wicklund Holding Company. Creating the immediate reduction of the value of Wicklund stock and its inability to ever pay Debtor his back salary. Accordingly, if forced to liquidate, the sale of the Debtor's assets would yield minimum in proceeds due to the fact that the only entity of any value would fail. Although a Chapter 7 Trustee is empowered to sell assets of a Debtor's estate, it is anticipated that Secured Creditors would not allow the Trustee to sell their security and would most likely be successful in obtaining a termination of the Automatic Stay. Likewise, it is unlikely that a Trustee would undertake the management of Wicklund. Consequently, the Debtor would have a minimum in funds available for distribution as any value in his principal assets would be lost. After payment of all Bankruptcy Court approved administrative expenses, priority claims, and claims which would arise as a result of a conversion to Chapter 7 and payment of Debtor’s Chapter 11 administrative expenses, the Debtor anticipates that no assets would remain available for distribution to creditors. Therefore, should the Plan not be implemented, the unsecured creditors, after all administrative expenses, priority claims and secured debts were satisfied, would receive no money on liquidation.
XI FEASIBILITY AND BEST INTEREST TESTS
For purposes of determining whether the Plan meets the feasibility test, Debtor believes that he has the ability to meet his obligations under the Plan and that same is feasible. Debtor is now employed as Managing Partner of Show Me Ink, LLC, a company that dates to 1906. The Debtors salary of $175,000.00 and 10% of sales and commissions (minimum of $50,000.00 annually based on historical records) allow him to meet his obligations as presented in this Plan.
Additionally, Debtor is waiting for final FDA approval of the “Sports Patch” whose inventors predict first year sales of $25 million dollars. They have entered into an agreement with PC, Inc., an affiliate of Wicklund for PC Inc.’s marketing and distribution of patch and products in exchange for which the inventors will receive ten percent of PC Inc.’s net sales. This device measures and predicts when an individual is about to have a stroke or heart attack. It has been tested successfully on a nationally ranked Florida football team and upon final FDA approval, the marketing of same will begin.
In addition to the sports patch referenced above, a WHC affiliate has recently completed a several million dollar acknowledgee sale, the proceeds of which will be received over the next several years. This information has recently been cleared for release to the public and should be released in the immediate future.
Debtor’s personal Wicklund Holding Company stock, while having the same value as any shareholders, is regulated by Rule 144 of the 1934 Security Act. This Rule provides the means by which debtor or a control person or officer, can sell their stock. Specifically, debtor can only sell a small percentage based on current trading volumes or a small percentage per month based on ownership. This control prevents the debtor or others from benefitting at the expense of other stockholders. Wicklund’s offering in the Plan of WHC Treasury Stock as a legal consideration in trading company debt for stock, provides for a reasonable release of stock and provides a means to settle WHC debts and Debtors guaranty of those Wicklund debts. So long as WHC debt is cancelled in exchange for WHC treasury stock and pursuant to SEC Rule 144(e) the treatment provided in Debtor’s Plan of Wicklund providing its stock for satisfaction of its debt and Debtor’s guaranty of those debts is permissible.
In summary, Debtor’s annual income of $175,000.00, and minimum of $50,000.00 in bonuses as well as his wife’s salary of $43,000.00 (she contributes her share), together with the prior assumption of some obligations and his or his wife’s payment of others allows him to make the payments in this Plan.
Debtor has attached a chart at Exhibit “A” which covers the period January 1, 2005 through December 31, 2006 and which consists of a budget showing projected revenue per month and
personal expenses per month. A review of the chart indicates that Mr. Turek will have the ability to meet the payments
required under his Second Amended Chapter 11 Plan. The attached chart may be modified prior to confirmation due to changes in amounts of claims attributable to interest accruing and to correct any errors which may be discovered prior to confirmation.
XII. CONFIRMATION BY CRAM DOWN
The Debtor reserves the right, in the event that impaired classes reject the Plan, to seek confirmation of the Plan pursuant to 11 U.S.C. § 1129(b) of the Bankruptcy Code if the Court finds that the Plan does not discriminate unfairly and is fair and equitable with respect to each dissenting class.
XIII. ADDITIONAL DISCLOSURES
A. There are no payments or promise made of the kind referenced in §1129(a)(5)(A) and (B) of the Bankruptcy Code (which relate to the identity of and promises made to insiders of Debtor) which have not previously been disclosed to the Court, creditors and other parties in interest.
B. As Debtor is an individual, the Plan does not affect ownership of Debtor’s assets remaining with Debtor after confirmation.
XIV. MISCELLANEOUS PROVISIONS
A. Notwithstanding any other provisions of the Plan, any claim which is scheduled as disputed, contingent, or unliquidated or which is objected to in whole or in part on or before the date for distribution on account of such claim shall not be paid in accordance with the provisions of the Plan until and unless such claim has become an Allowed Claim by a final order. If allowed, the claim shall be paid on the same terms provided for that Class under Debtor’s Plan as if there had
been no dispute.
B. At any time before the Confirmation Date, the Debtor may amend or modify the Plan or portions thereof so long as the Plan, as amended or modified, meets the requirements of Sections 1122 and 1123 of the Bankruptcy Code. After the Debtor files a modification with the Bankruptcy Court, the Plan, as modified, shall become the Plan.
C. At any time after the Confirmation Date, and before substantial consummation of the Plan, the Reorganized Debtor may modify the plan so long as the Plan, as modified, meets the requirements of Sections 1122 and 1123 of the Bankruptcy Code. The Plan, if modified under this paragraph, shall become the Plan.
D. After the Confirmation Date, the Debtor may, with approval of the Bankruptcy Court, and so long as it does not materially and adversely affect the interest of creditors, remedy any defect or omission, or reconcile any inconsistencies in the Plan or in the Order of Confirmation, in such manner as may be necessary to carry out the purposes and effect of the Plan.
XV. CONCLUSION
Under the Debtor's Plan, all Claimants of the Debtor with allowed claims will participate in some manner in the distribution to be made thereunder, and all creditors shall be paid all of their claim, which is far greater than any recovery they will obtain under a Chapter 7 Bankruptcy Proceeding. The Debtor believes that the distributions contemplated in his Plan are fair and afford all Claimants and Interest Holders equitable treatment.
ACCORDINGLY, THE DEBTOR RECOMMENDS THAT ALL CLAIMANTS VOTE TO ACCEPT THE PLAN.
I hereby verify that all of the information contained in this First Amended Disclosure Statement is true and correct to the best of my knowledge and belief.
/s/ C. Edwin Rude, Jr., Esquire
C. EDWIN RUDE, JR., ESQUIRE
Florida Bar No. 0157985
322 McDaniel Street
Tallahassee, Florida 32303
Telephone (850) 224-2422
Facsimile (850) 224-0762
Attorney for Debtor |
