Case KCF Doc 12 Filed 07/21/14 Entered 07/21/14 18:47:10 Desc Main Document Page 1 of 9

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1 Case KCF Doc 12 Filed 07/21/14 Entered 07/21/14 18:47:10 Desc Main Document Page 1 of 9 LOWENSTEIN SANDLER LLP Kenneth A. Rosen, Esq. Jeffrey D. Prol, Esq. Ira M. Levee, Esq. 65 Livingston Avenue Roseland, New Jersey (973) (Telephone) (973) (Facsimile) Proposed Counsel to the Debtors and Debtors-in-Possession UNITED STATES BANKRUPTCY COURT DISTRICT OF NEW JERSEY In re: Cloudeeva, Inc., 1 Debtors. Chapter 11 Case No (KCF) (Joint Administration Requested) MOTION FOR APPROVAL OF PROPOSED FACTORING AGREEMENT AND ORDER AUTHORIZING IMMEDIATE FINANCING The above-captioned debtors and debtors-in-possession (collectively, the Debtors ), by and through their proposed counsel, submit this motion (the Motion ) for entry of an order (the Proposed Order ) substantially in the form submitted herewith authorizing the Debtors to enter into a Post-Petition Factoring arrangement with Prestige Capital Corporation ( Prestige ), pursuant to the terms and conditions of the Proposed Factoring Agreement, annexed hereto as Exhibit A (the Proposed Factoring Agreement ). In support of the Motion, Debtors submit the Declaration in Support of Chapter 11 Petitions and First Day 1 The Debtors in these chapter 11 cases, along with the last four digits of each Debtor s tax identification number, are: Cloudeeva, Inc., a Delaware Corporation (5326) and Cloudeeva, Inc., a Florida Corporation (2227). Cloudeeva, Inc., a Delaware Corporation s corporate headquarters are located at 104 Windsor Center Drive, Suite 300, East Windsor, New Jersey /2 07/21/

2 Case KCF Doc 12 Filed 07/21/14 Entered 07/21/14 18:47:10 Desc Main Document Page 2 of 9 Pleadings (the First Day Declaration ), filed contemporaneously herewith, and respectfully state as follows: JURISDICTION 1. This Court has jurisdiction over this Motion pursuant to 28 U.S.C. 157 and 1334 and the Standing Order of Reference to the Bankruptcy Court Under Title 11 dated as of September 18, 2012 (Simandle, C.J.). Venue is proper in this district pursuant to 28 U.S.C and This matter is a core proceeding pursuant to 28 U.S.C. 157(b)(2). 2. The statutory predicates for the relief sought herein are sections 105(a) and 364, of title 11 of the United States Code (the Bankruptcy Code ), Rule 4001 of the Federal Rules of Bankruptcy Procedure (the Bankruptcy Rules ), and the applicable Local Bankruptcy Rules for the United States Bankruptcy Court for the District of New Jersey (the Local Rules ). BACKGROUND 3. On the date hereof (the Petition Date ), each of the Debtors filed a voluntary petition for relief under chapter 11 of the Bankruptcy Code (collectively, the Chapter 11 Cases ). 4. The Debtors are operating their businesses and managing their properties as debtors-in-possession pursuant to sections 1107(a) and 1108 of the Bankruptcy Code. As of the filing of this Motion, no trustee, examiner or creditors committee has been requested or appointed. 5. Additional background facts surrounding the commencement of these Chapter 11 Cases are more fully described in the First Day Declaration. RELIEF REQUESTED 6. As is more fully set forth herein, pending a final hearing on the Proposed Factoring Order, the Debtors respectfully request an interim hearing authorizing the Debtors to -2-

3 Case KCF Doc 12 Filed 07/21/14 Entered 07/21/14 18:47:10 Desc Main Document Page 3 of 9 factor the Accounts in order to raise funds from Prestige to enable them to continue operations. Absent immediate temporary financing, the Debtors will likely be forced to cease operating, resulting in the loss of jobs and rendering unlikely the Debtors reorganization for the benefit of their creditors and the estates. PROPOSED FACTORING AGREEMENT 7. By the Factoring Motion, Debtors seek interim and final approval of a factoring agreement with Prestige. 8. Historically, the Debtors did not have any secured debt. Rather, Debtors used cash on hand and cash flow from operations to fund working capital, merchandise purchases, service provider fees and expenses, capital expenditures, and other general corporate expenses. 9. In order to protect the value of the Debtors pending the outcome of litigation with Bartronics Asia, the California Superior Court entered an order on October 15, 2013, a copy of which is annexed as Exhibit B, granting a preliminary injunction prohibiting the Debtors from encumbering any assets of Cloudeeva, Inc., a Delaware corporation or using any assets of Cloudeeva, a Delaware corporation, as collateral for any loan (sic) pending the outcome of that litigation. As a result of costs incurred in connection with the litigation with Bartronics Asia and interruptions in the Debtors business caused by Bartronics Asia, Debtors suffered a severe cash flow crisis in early In order to meet operating expenses, Debtors sought authority from the California Superior Court to enter into a factoring agreement. By order entered on March 10, 2014, a copy of which is annexed as Exhibit C, the California Superior Court modified the preliminary injunction to allow the Debtors to factor their receivables on a limited basis. 10. On March 13, 2014, the Debtors entered into a factoring agreement with Prestige (the Factoring Agreement ), annexed as Exhibit D. Pursuant to the terms of the Factoring Agreement, Prestige would pay Debtors eighty percent of the face value of accounts sold under -3-

4 Case KCF Doc 12 Filed 07/21/14 Entered 07/21/14 18:47:10 Desc Main Document Page 4 of 9 the Factoring Agreement up to a maximum amount of $2,000,000 (the Maximum Advance ). Prestige would then hold in reserve the difference between the purchase price for the receivables purchased and the 80% down payment. Provided that there were no outstanding chargebacks or disputes, Prestige would pay the reserve, less any sums due Prestige within five business days of the date on which the accounts were collected. Per the Factoring Agreement, Prestige would earn a fee on each account purchased based on a sliding scale depending on when the account was collected. For example, Prestige would earn a fee of 2.15% if the account was paid within 30 days and a fee of 2.87% if the account was paid within 40 days. Prestige s fee continued to increase as the time of collection increased. See Exhibit E and 14, infra. The obligations due to Prestige are also secured by a lien on the Debtors accounts, inventory, machinery and equipment, instruments, documents, chattel paper and general intangibles, and the proceeds thereof ( Pre-Petition Collateral ). Prestige caused to be filed a UCC-1 Financing Statement to perfect its interest in the Pre-Petition Collateral. The obligations to Prestige are further secured by the personal guarantee of the Debtors chairman and CEO, Adesh Tyagi. Prestige s willingness to enter into the Factoring Agreement was further conditioned on Mr. Tyagi remaining in control of the Debtors. 11. Because the Debtors liquidity crisis turned out to be more severe than originally anticipated the Debtors sought further modification of the preliminary injunction to approve an increase in the amount of accounts factored to meet operating expenses and to expand the authority to factor additional receivables going forward. The California Superior Court denied this request in an Order entered on June 9, 2014, a copy of which is annexed as Exhibit F, ruling: Given the apparent difficulty defendant has had in estimating the duration of the need for and the actual costs of factoring and in -4-

5 Case KCF Doc 12 Filed 07/21/14 Entered 07/21/14 18:47:10 Desc Main Document Page 5 of 9 complying with the court s conditions placed on obtaining factoring, this court is unwilling to further extend the exception to allow the company to increase its operating costs and/or to incur debtor while this action is pending... Defendant must explore other ways in which to meet its payroll obligations on (sic) the short term. 12. As of the date of the filing of the Petitions herein, Debtors' obligation to Prestige was approximately $150, As set forth in the Proposed Factoring Agreement, Prestige has agreed to finance the Debtors' post-petition operations under the same terms and conditions as the March 14 Factoring Agreement, except that Prestige has agreed to make funds available to the Debtors by advancing to the Debtors eighty (80%) percent of eligible accounts receivable (the Post- Petition Advances ) with a maximum outstanding balance of $3,000,000; in addition, Debtors shall pay a one-time accommodation fee in the amount of $4,000 to Prestige. In all other respects, the terms of the Factoring Agreement remain the same and in full force and effect. The Post-Petition Advances shall be secured by a first lien and security interest on all of the Debtors' post-petition assets (the Post-Petition Collateral ). See 11 U.S.C. 364(c)(2). 14. As set forth in the Factoring Agreement, Customers whose receivables (the Accounts ) are financed with Prestige will make payments directly to Prestige who will accept and endorse the checks and deposit same into its account. Prestige will hold in reserve (the Reserve ) the difference between the Post-Petition Advance and the net face value of the Account less the fees (described supra) and any chargeback as described in paragraph 3 of the Post-Petition Factoring Agreement. Within five (5) business days of collection in good funds of the Account, Prestige will pay Debtors the Reserve amount. In addition to the fees charged based upon the number of days the Account is outstanding from the date of the Post-Petition Advance (see Exhibit E), which is deducted from the face value of the Account upon collection, -5-

6 Case KCF Doc 12 Filed 07/21/14 Entered 07/21/14 18:47:10 Desc Main Document Page 6 of 9 should the aggregate of the Account be less than $1.5 Million (the Minimum ) in any ninety (90) day period, then an additional fee of 2.15% of the shortfall (from the Minimum) will be charged on the last day of the 90-day period. 15. As an IT consulting and staffing business, Cloudeeva must pay its employees before it receives payment for the services the employees render to vendors and customers. Cloudeeva must either build a significant cash reserve in order to meet payroll, including payroll insurance, workers compensation and payroll taxes to local, state and federal governmental agencies, or Cloudeeva must raise funds through factoring its receivables. 16. The Debtors are presently unable to obtain funds which are necessary for it to continue operations in the form of unsecured credit pursuant to 364(a) and (b) of the Bankruptcy Code. 17. The Proposed final (Exhibit G) and interim (Exhibit H) Orders provide that, pursuant to 364(c)(1) and (c)(2) of the Bankruptcy Code, the Post-Petition Advances shall (i) be considered Chapter 11 administrative claims and shall be granted super priority status over all administrative expenses incurred by the Debtors with the exception of fees due the United States Trustee pursuant to 28 U.S.C. 1930(a) and to the professionals retained by the Debtors and the Unsecured Creditors Committee (if appointed); and (ii) be secured by a lien on property of the Bankruptcy Estates that is not otherwise subject to a lien; and by a junior lien on any property of the Bankruptcy Estates that is subject to a prior lien. Further, the Debtors have expressly waived any right it has to charge the Pre- or Post-Petition Collateral with any costs or expense pursuant to 506(c) of the Bankruptcy Code. 18. In order to adequately protect Prestige s interest in the Pre-Petition Collateral, the proposed Order provides that relief from the automatic stay shall be granted to, inter alia, permit -6-

7 Case KCF Doc 12 Filed 07/21/14 Entered 07/21/14 18:47:10 Desc Main Document Page 7 of 9 Prestige to assert its rights to and realize upon all pre-petition assets in which Prestige has a security interest and directing the Debtors to pay any collections on the pre-petition receivables received by the Debtors to Prestige. The Order also provides for relief from the automatic stay to the extent necessary to permit the Debtors to continue to sell their accounts to Prestige in accordance with the Proposed Factoring Order and to permit Prestige to administer the Pre- Petition Factoring and Post-Petition Factoring Agreements and collect the accounts in the ordinary course of its business. Additionally, the stay is modified to permit the execution and filing of any financing statements necessary for the perfection of the liens and security interests granted to Prestige by the Proposed Factoring Order. 19. The Proposed Order also authorizes the Debtors promptly to reimburse Prestige for all costs incurred in connection with the Proposed Factoring Order, including all of the reasonable legal fees and expenses of counsel to Prestige, all of which costs and expenses are to be included in the amount of Post-Petition Advances. 20. Finally, in the event of the Debtors failure to perform their obligations under the Proposed Order, the occurrence of any default by the Debtors under the Proposed Order, or the subordination of any security interest of Prestige or upon other specified events, Prestige, upon ten days notice, shall be granted relief from the stay pursuant to 362(d) of the Bankruptcy Code, to permit it to assert its rights as a secured party as provided in the Pre- and Post-Petition Financing Agreements and to enforce its security interest against its collateral. THE NEED FOR IMMEDIATE RELIEF 21. It is necessary for the proper operation of the business of the Debtors to enter into the proposed agreement with Prestige whereby Prestige will make funds available to permit the Debtors to continue to operate their business through the Chapter 11 process. Thus, it is essential for the continued operation of the Debtors business that the Debtors have immediate cash -7-

8 Case KCF Doc 12 Filed 07/21/14 Entered 07/21/14 18:47:10 Desc Main Document Page 8 of 9 availability of up to $2 million. The Debtors require immediate funds to meet payroll and other expenses, including certain tax arrearages. If the Debtors are unable to obtain financing from Prestige as the Debtors did pre-petition, the business of the Debtors will be adversely affected in that the Debtors will lose critical cash flow and will be unable to satisfy their payroll obligations and continue their operations. 22. Debtors submit this Motion pursuant to 11 U.S.C. 364 and Bankruptcy Rules 4001 and 9014 and request that an emergency hearing take place, and at such hearing an interim Order be entered authorizing the Debtors to raise funds from Prestige on the terms and conditions of the Interim Order pending the final hearing to avoid immediate and irreparable harm to the estate at which time the Debtors will seek an Order authorizing the Debtors to enter into the Agreement. 23. Annexed hereto and marked as Exhibit I is a 13-week cash flow budget indicating cash needs from Prestige to pay operating expenses, including payroll, rent, utilities and other expenses. If the authority herein sought is not granted, the Debtors will not be able to meet their essential expenses and will be unable to preserve their assets for the benefit of their estates and creditors. In such event, all creditors and parties in interest will suffer irreparable harm, including the loss of any expectation of recovery from the estates. 24. For the above reasons, the Debtors submit that sufficient grounds exist to permit limited interim financing pending the final hearing on this Motion, pursuant to 364(c) of the Bankruptcy Code. WAIVER OF MEMORANDUM OF LAW 25. Because the legal points and authorities upon which this Motion relies are incorporated herein and do not raise any novel issues of law, the Debtors respectfully request that -8-

9 Case KCF Doc 12 Filed 07/21/14 Entered 07/21/14 18:47:10 Desc Main Document Page 9 of 9 the requirement of the service and filing of a separate memorandum of law pursuant to Local Rule be deemed waived. NO PRIOR REQUEST 26. No previous motion for the relief sought herein has been made to this or to any other Court. NOTICE 27. Notice of this Motion has been given to (i) the Office of the United States Trustee for the District of New Jersey; (ii) the Debtors twenty largest unsecured creditors; (iii) counsel to Prestige; (iv) those parties listed on the Debtors Core Service list; and (v) those parties who have filed a notice of appearance and request for service of pleadings in these Chapter 11 Cases pursuant to Bankruptcy Rule In light of the nature of the relief requested herein, the Debtors submit that no other or further notice is required. WHEREFORE, the Debtors respectfully request that this Court: (i) enter interim and final orders, substantially in the forms submitted herewith, granting the relief requested herein; and (ii) grant the Debtors such other and further relief as the Court deems just and proper. Dated: July 21, 2014 Respectfully submitted, LOWENSTEIN SANDLER LLP /s/ Jeffrey D. Prol Kenneth A. Rosen, Esq. Jeffrey D. Prol, Esq. Ira M. Levee, Esq. 65 Livingston Avenue Roseland, New Jersey (973) (Telephone) (973) (Facsimile) Proposed Counsel to the Debtors and Debtors-in-Possession -9-

10 Case KCF Doc 12-1 Filed 07/21/14 Entered 07/21/14 18:47:10 Desc Exhibit A Page 1 of 2

11 Case KCF Doc 12-1 Filed 07/21/14 Entered 07/21/14 18:47:10 Desc Exhibit A Page 2 of 2

12 Case KCF Doc 12-2 Filed 07/21/14 Entered 07/21/14 18:47:10 Desc Exhibit B Page 1 of 6

13 Case KCF Doc 12-2 Filed 07/21/14 Entered 07/21/14 18:47:10 Desc Exhibit B Page 2 of 6

14 Case KCF Doc 12-2 Filed 07/21/14 Entered 07/21/14 18:47:10 Desc Exhibit B Page 3 of 6

15 Case KCF Doc 12-2 Filed 07/21/14 Entered 07/21/14 18:47:10 Desc Exhibit B Page 4 of 6

16 Case KCF Doc 12-2 Filed 07/21/14 Entered 07/21/14 18:47:10 Desc Exhibit B Page 5 of 6

17 Case KCF Doc 12-2 Filed 07/21/14 Entered 07/21/14 18:47:10 Desc Exhibit B Page 6 of 6

18 Case KCF Doc 12-3 Filed 07/21/14 Entered 07/21/14 18:47:10 Desc Exhibit C Page 1 of 4

19 Case KCF Doc 12-3 Filed 07/21/14 Entered 07/21/14 18:47:10 Desc Exhibit C Page 2 of 4

20 Case KCF Doc 12-3 Filed 07/21/14 Entered 07/21/14 18:47:10 Desc Exhibit C Page 3 of 4

21 Case KCF Doc 12-3 Filed 07/21/14 Entered 07/21/14 18:47:10 Desc Exhibit C Page 4 of 4

22 Case KCF Doc 12-4 Filed 07/21/14 Entered 07/21/14 18:47:10 Desc Exhibit D Page 1 of 9

23 Case KCF Doc 12-4 Filed 07/21/14 Entered 07/21/14 18:47:10 Desc Exhibit D Page 2 of 9

24 Case KCF Doc 12-4 Filed 07/21/14 Entered 07/21/14 18:47:10 Desc Exhibit D Page 3 of 9

25 Case KCF Doc 12-4 Filed 07/21/14 Entered 07/21/14 18:47:10 Desc Exhibit D Page 4 of 9

26 Case KCF Doc 12-4 Filed 07/21/14 Entered 07/21/14 18:47:10 Desc Exhibit D Page 5 of 9

27 Case KCF Doc 12-4 Filed 07/21/14 Entered 07/21/14 18:47:10 Desc Exhibit D Page 6 of 9

28 Case KCF Doc 12-4 Filed 07/21/14 Entered 07/21/14 18:47:10 Desc Exhibit D Page 7 of 9

29 Case KCF Doc 12-4 Filed 07/21/14 Entered 07/21/14 18:47:10 Desc Exhibit D Page 8 of 9

30 Case KCF Doc 12-4 Filed 07/21/14 Entered 07/21/14 18:47:10 Desc Exhibit D Page 9 of 9

31 Case KCF Doc 12-5 Filed 07/21/14 Entered 07/21/14 18:47:10 Desc Exhibit E Page 1 of 2

32 Case KCF Doc 12-5 Filed 07/21/14 Entered 07/21/14 18:47:10 Desc Exhibit E Page 2 of 2

33 Case KCF Doc 12-6 Filed 07/21/14 Entered 07/21/14 18:47:10 Desc Exhibit F Page 1 of 6

34 Case KCF Doc 12-6 Filed 07/21/14 Entered 07/21/14 18:47:10 Desc Exhibit F Page 2 of 6

35 Case KCF Doc 12-6 Filed 07/21/14 Entered 07/21/14 18:47:10 Desc Exhibit F Page 3 of 6

36 Case KCF Doc 12-6 Filed 07/21/14 Entered 07/21/14 18:47:10 Desc Exhibit F Page 4 of 6

37 Case KCF Doc 12-6 Filed 07/21/14 Entered 07/21/14 18:47:10 Desc Exhibit F Page 5 of 6

38 Case KCF Doc 12-6 Filed 07/21/14 Entered 07/21/14 18:47:10 Desc Exhibit F Page 6 of 6

39 Case KCF Doc 12-7 Filed 07/21/14 Entered 07/21/14 18:47:10 Desc Exhibit G Page 1 of 10 EXHIBIT G

40 Case KCF Doc 12-7 Filed 07/21/14 Entered 07/21/14 18:47:10 Desc Exhibit G Page 2 of 10

41 Case KCF Doc 12-7 Filed 07/21/14 Entered 07/21/14 18:47:10 Desc Exhibit G Page 3 of 10

42 Case KCF Doc 12-7 Filed 07/21/14 Entered 07/21/14 18:47:10 Desc Exhibit G Page 4 of 10

43 Case KCF Doc 12-7 Filed 07/21/14 Entered 07/21/14 18:47:10 Desc Exhibit G Page 5 of 10

44 Case KCF Doc 12-7 Filed 07/21/14 Entered 07/21/14 18:47:10 Desc Exhibit G Page 6 of 10

45 Case KCF Doc 12-7 Filed 07/21/14 Entered 07/21/14 18:47:10 Desc Exhibit G Page 7 of 10

46 Case KCF Doc 12-7 Filed 07/21/14 Entered 07/21/14 18:47:10 Desc Exhibit G Page 8 of 10

47 Case KCF Doc 12-7 Filed 07/21/14 Entered 07/21/14 18:47:10 Desc Exhibit G Page 9 of 10

48 Case KCF Doc 12-7 Filed 07/21/14 Entered 07/21/14 18:47:10 Desc Exhibit G Page 10 of 10

49 Case KCF Doc 12-8 Filed 07/21/14 Entered 07/21/14 18:47:10 Desc Exhibit H Page 1 of 11 EXHIBIT H

50 Case KCF Doc 12-8 Filed 07/21/14 Entered 07/21/14 18:47:10 Desc Exhibit H Page 2 of 11

51 Case KCF Doc 12-8 Filed 07/21/14 Entered 07/21/14 18:47:10 Desc Exhibit H Page 3 of 11

52 Case KCF Doc 12-8 Filed 07/21/14 Entered 07/21/14 18:47:10 Desc Exhibit H Page 4 of 11

53 Case KCF Doc 12-8 Filed 07/21/14 Entered 07/21/14 18:47:10 Desc Exhibit H Page 5 of 11

54 Case KCF Doc 12-8 Filed 07/21/14 Entered 07/21/14 18:47:10 Desc Exhibit H Page 6 of 11

55 Case KCF Doc 12-8 Filed 07/21/14 Entered 07/21/14 18:47:10 Desc Exhibit H Page 7 of 11

56 Case KCF Doc 12-8 Filed 07/21/14 Entered 07/21/14 18:47:10 Desc Exhibit H Page 8 of 11

57 Case KCF Doc 12-8 Filed 07/21/14 Entered 07/21/14 18:47:10 Desc Exhibit H Page 9 of 11

58 Case KCF Doc 12-8 Filed 07/21/14 Entered 07/21/14 18:47:10 Desc Exhibit H Page 10 of 11

59 Case KCF Doc 12-8 Filed 07/21/14 Entered 07/21/14 18:47:10 Desc Exhibit H Page 11 of 11

60 Case KCF Doc 12-9 Filed 07/21/14 Entered 07/21/14 18:47:10 Desc Exhibit I Page 1 of 2 EXHIBIT I

61 Case KCF Doc 12-9 Filed 07/21/14 Entered 07/21/14 18:47:10 Desc Exhibit I Page 2 of 2 Cloudeeva Inc Case No (KCF) 13 WEEK CASH FORECAST Week ending Saturday 25-Jul 1-Aug 8-Aug 15-Aug 22-Aug 29-Aug 5-Sep 12-Sep 19-Sep 26-Sep 3-Oct 10-Oct 17-Oct TOTAL Cash, beginning of period $ 68,000 $ 120,376 $ 167,388 $ 2,218,228 $ 319,607 $ 570,255 $ 502,138 $ 1,490,378 $ 682,774 $ 867,849 $ 725,112 $ 1,353,353 $ 1,013,706 $ 68,000 Accounts receivable collected 650, , , , , , , , , , , , ,075 4,754,625 Sales 650, , , , , , , , , , , , ,023 8,660,088 Consultant Salary & Wages ,388, ,430, ,473,506-4,293,016 Payroll Taxes , , , ,547 Performance Bonus Sub Contractor Charges , , , ,237 Immigration fee's - Visa - Refund 24,000 24,000 24,000 24, ,000 Consultants Benefits - 24,604-24,604-24,604-24,604-24,604-24, ,623 Sales - Salaries & Wages - 51,016-51,016-51,016-51,016-51,016-51, ,097 Incentives- - 5,298-5,298-5,456-5,456-5,620-5,620-32,748 Payroll Taxes - 3,987-3,987-4,107-4,107-4,230-4,230-24, k Employer Contribution-Sale ,995 Benefits- Sales , , ,747-22,570 Sales Expenses - 18,893-9,223-9,223-9,499-9,499-9,784-66,121 Recruitment - Salaries & Wages- - 32,561-32,561-33,538-33,538-34,544-34, ,284 Incentives-Recruitment - 1,700-1,700-1,751-1,751-1,804-1,804-10,509 Payroll Taxes - 2,509-2,509-2,585-2,585-2,662-2,662-15, k Employer Contribution-Rect Benefits -Recruitment ,274 Travel Expenses - 2,202-2,789-2,268-2,872-2,336-2,958-15,426 Training Cost - Salaries & Wages-Training - 12,156-12,156-12,520-12,520-12,896-12,896-75,144 Incentives-Trainig , , ,028-8,822 Payroll Taxes , k Employer Contrib-Train Benefits -Training ,525 Expenses - 6,854-6,854-7,059-7,059-7,271-7,271-42,368 Admin Cost - Salaries & Wages-Admin - 42,254-42,254-43,521-43,521-44,827-44, ,204 Incentives-Admin - 3,079-3,833-3,171-3,948-3,266-3,266-20,564 Payroll Taxes , k Employer Contrib-Admin Expenses Officers Cost - Salaries & Wages-Officer - 57,708-57,708-57,708-59,440-57,708-57, ,981 Incentive , , , ,200 Payroll Taxes - 3,409-3,409-3,409-3,511-3,409-3,409-20, k Employer Contributions ,317 Benefits - 5,189 4,652 5,189-5,189 4,652 5,345-5,189 4,652 5,189-45,246 Travel , , , ,000 Outsourced Admin Payroll , , ,000 Office Rent 31, , , , ,103 Rent Office Maintanence 7, , , ,414 29,657 Liability Insurance , , , ,930 Corporate Attorney , , ,000 Expert Witness Fee , , ,000 Accounting, Tax & Audit Service , , , ,500 Other Sub Contractor Services 12, ,325 Payroll Service Charges , , ,103-6,126 Utilities - - 2, , , ,020 Stationary & Computer Exp - - 6, , , ,997 Factoring fee - 1,234-1,234-1,271-1,271-1,309-1,309-7,629 Chapter 11 professional fees (Escrow - TBD) Pre Petition Foreign Vendor 145, ,000 Pre Petition Payroll Taxes 50,000 50,000 50,000 50,000 50,000 50,000 50,000 50,000 50,000 50,000 50,000 50, ,000 1,180,000 Pre Petition 401(k) Contributions 25, ,306 Pre Petition Critical Vendors 302, , ,325 78, , ,451,256 TOTAL EXPENSES 597, , ,959 2,130, , ,968 81,634 2,277,479 85, , ,634 2,289, ,690 10,686,134 Factoring Borrowing - 2,000, , ,000 1,200, ,000 1,680,000 6,480,000 Bank Charges ,400 Cash, End of Period $ 120,376 $ 167,388 $ 2,218,228 $ 319,607 $ 570,255 $ 502,138 $ 1,490,378 $ 682,774 $ 867,849 $ 725,112 $ 1,353,353 $ 1,013,706 $ 615,091 $ 615,091

62 Case KCF Doc Filed 07/21/14 Entered 07/21/14 18:47:10 Desc proposed interim Order Page 1 of 10

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72 Case KCF Doc Filed 07/21/14 Entered 07/21/14 18:47:10 Desc proposed Final Order Page 1 of 9

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