PADDA Hotels LLC

UNITED STATES BANKRUPTCY COURT
DISTRICT OF NEW MEXICO
In re:
PADDA HOTELS, LLC, 	No. 12-13786 TA
Debtor.
MEMORANDUM OPINION
The Debtor owns a Hampton Inn (the “Hotel”) in Clovis, New Mexico, encumbered by
first and second mortgages held by State Bank of Texas (the “Bank”). Purchased just before the
Great Recession of 2008, the Hotel ran into financial trouble, resulting in a foreclosure action
and this bankruptcy case. 	The Debtor filed a plan of reorganization1 that proposes to pay the
Bank and other creditors 100% of their claims, plus interest. 	The Bank objected on feasibility
grounds, and also filed a motion to dismiss the case.2 On January 29, 2014, the Court held final
hearings on Plan confirmation and the Motion to Dismiss. 	For the reasons set forth below, the
Court concludes that the Plan should be confirmed and the Motion to Dismiss denied.
II. 	Findings of Fact
The Court makes the following findings of fact:
1. 	The Debtor, a New Mexico limited liability company, owns the 55-room Hotel,
which is located in Clovis, New Mexico. The Hotel has been operated as a Hampton Inn since at
least 2007.
2. 	Ms. Jasbir Kaur and her husband formed the Debtor and bought the Hotel for
$4,500,000 in late 2007.
1 Amended and Restated Chapter 11 Plan, doc. 76, (the “Plan”).
2 Motion to Dismiss Chapter 11 Proceeding, doc. 58 (the “Motion to Dismiss”).
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3. 	The Kaurs invested their life savings ($800,000-$900,000) to buy and refurbish
the Hotel, and financed the balance of the purchase price with a $2,252,600 first mortgage loan
from Millennium State Bank of Texas (the “Millennium Loan”) and a $1,613,000 second
mortgage loan from the United States Small Business Administration (the “SBA Loan”).3
4. 	The Bank now owns both loans.
5. 	Mr. Kaur thereafter became gravely ill from a brain hemorrhage and now is
completely disabled. The sole source of income for the Kaur family, including their 19-year old
daughter, is about $900 in monthly disability payments to Mr. Kaur and $4,500 monthly
management fees paid to Ms. Kaur by the Debtor.
6. 	The Debtor was hit hard by the 2008 financial crisis, and has been recovering ever
since.
7. 	The Bank filed a foreclosure action in January 2012, prompting the Debtor to seek
Chapter 11 relief on October 16, 2012.
8. 	The Kaurs mortgaged their California house to raise money to refurbish the Hotel,
and have since lost the home to foreclosure.
9. 	The Debtor retained Hotel Management Solutions (“HMS”) in April 2009, after
the Hotel failed a franchisor inspection. 	Under HMS’ management, the Hotel has passed all
subsequent franchisor inspections.
10. 	The Hotel’s revenues went from $1,125,831.42 in 2011 to $1,229,518.88 in 2013,
a 9.2% increase. During that time the occupancy rate held steady at about 72.4%.
3 The loans are reflected in proofs of claim 4 (SBA Loan) and 5 (the Millennium Loan).
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11. 	Since 2011 the Debtor’s average daily room rate increased from $76.60 to $84.50,
about a 10% increase.
12. 	HMS prepared a Marketing Plan for the Hotel (the “Marketing Plan”). 	The
Marketing Plan discloses, among other information, that the current average daily room rate for
the Debtor’s competitors in Clovis is $89.14.
13. 	The Debtor’s plan is to increase its average daily rate to that of the competition
(about a 5% increase), while keeping occupancy, and therefore operating expenses, steady.
14. 	The Plan proposes to pay the Millennium Loan and the SBA Loan in full, with
4.75% interest, amortized over 30 years. 	The Plan also proposes to pay general unsecured
creditors 100% of their claims over time, plus interest at 3%.
15. 	The Debtor objected to the Bank’s secured claims. 	Despite the pending claim
objections, the parties stipulated that the Bank’s claims could be temporarily allowed for voting
purposes. 	Furthermore, the parties stipulated that for the purpose of analyzing Plan feasibility,
the Millennium Loan should be valued at $2,252,600.
16. 	Based on a $2,252,600 amount, the monthly payment to the Bank on the
Millennium Loan would be $11,476.24.
17. 	The Bank voted against the Plan and objected to the Plan on feasibility grounds.
General unsecured creditors voted in favor of the Plan.
18. 	At the final hearing, the Bank conceded that the Plan satisfies the “cramdown”
elements of § 1129(b).4
4 Unless otherwise noted, all statutory references are to 11 U.S.C.
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19. 	The Debtor and New Mexico Taxation and Revenue (“TRD”) stipulated that the
monthly payment to TRD under the Plan on account of its priority claim should be increased to
$4,082.08, and paid through October 2017.
20. 	The Debtor’s projections for future income and expenses are based on past
performance.
21. 	As 	of 	January 	29, 	2014 	the 	Debtor 	had 	cash 	reserves 	of 	approximately
$130,000.00.
22. 	Post-petition, the Debtor paid its delinquent property taxes to Curry County and
cured the delinquencies in franchise payments.
23. 	The Debtor prepared a five year cash flow projection, attached as Exhibit B to the
Debtor’s disclosure statement (the “Cash Flow Projection”).
III. 	Plan Confirmation
A. 	Compliance with § 1129.
The Court has an “independent duty to ensure that the requirements of 11 U.S.C. § 1129
are satisfied, even if no objections to confirmation have been made.” 	In re Young Broad. Inc.,
430 B.R. 99, 139 (Bankr. S.D.N.Y. 2010); In re Williams, 850 F.2d 250, 253 (5th Cir. 1988)
(court “has a mandatory independent duty to determine whether the plan has met all of the
requirements necessary for confirmation”); In re Ambanc La Mesa Ltd. P’ship, 115 F.3d 650,
653 (9th Cir. 1997) (“The bankruptcy court had an affirmative duty to ensure that the Plan
satisfied all 11 U.S.C. § 1129 requirements for confirmation.”); In re Lett, 632 F.3d 1216, 1220
(11th Cir. 2011) (same). Here, the Bank’s objection to confirmation is limited to feasibility under
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§ 1129(a)(11). Nevertheless, the Court will review the evidence to see if the Plan complies with
the remaining requirements of § 1129.
B. 	§§ 1129(a)(1)-(a)(7), (a)(9), (a)(10), and (a)(12)-(a)(16)
The Bank voted against the Plan, so the Court will analyze the Plan’s compliance with §§
1129(a)(8) and 1129(b) below. 	Similarly, the “feasibility” requirement of § 1129(a)(11) is
discussed separately.
At the final hearing, the Debtor presented Ms. Kaur’s affidavit, which sets forth evidence
that the Plan complies with the requirements of § 1129(a). 	Ms. Kaur then testified that the
statements in the affidavit were based on her personal knowledge and were true and correct. The
Bank did not question Ms. Kaur about any of the statements in the Affidavit, other than the
statements relating to feasibility.
The Debtor also introduced into evidence a tally of ballots, together with the ballot of the
unsecured creditor that voted for the Plan.
Based on the docket and the uncontroverted evidence provided by the Debtor, the Court
finds that the Plan complies with the requirements of § 1129(a)(1)-(a)(7), (a)(9), (a)(10), and
(a)(12)-(a)(16).
C. 	§ 1129(b) (“Cramdown” of Secured Claims).
Since the Bank voted against the Plan, confirmation is only available if the “cramdown”
provisions of § 1129(b) are met. Section 1129(b) provides in pertinent part:
(b)(1) Notwithstanding section 510(a) of this title, if all of the applicable
requirements of subsection (a) of this section other than paragraph (8) are met
with respect to a plan, the court, on request of the proponent of the plan, shall
confirm the plan notwithstanding the requirements of such paragraph if the plan
does not discriminate unfairly, and is fair and equitable, with respect to each class
of claims or interests that is impaired under, and has not accepted, the plan.
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(2) For the purpose of this subsection, the condition that a plan be fair and
equitable with respect to a class includes the following requirements:
(A) With respect to a class of secured claims, the plan provides--
(i)(I) that the holders of such claims retain the liens securing such claims,
whether the property subject to such liens is retained by the debtor or transferred
to another entity, to the extent of the allowed amount of such claims; and
(II) that each holder of a claim of such class receive on account of such
claim deferred cash payments totaling at least the allowed amount of such claim,
of a value, as of the effective date of the plan, of at least the value of such holder's
interest in the estate's interest in such property ….
As stated in In re Inv. Co. of the Southwest, Inc., 341 B.R. 298 (10 th Cir. BAP 2006):
Subsection (b)(2)(A)(i) of § 1129 in essence allows the plan proponent to write a
new loan for full payment at a market rate of interest secured by the creditor's
prepetition collateral.
341 B.R. at 318.
The Plan satisfies § 1129(b)(2)(A)(i)(I) because the Bank will retain the liens securing
the Bank Claim and the SBA Claim. The remaining element ((A)(i)(II)) generally requires that a
secured creditor receive “a market rate of interest” on its claim. Id. Ms. Kaur testified that the
proposed rate of 4.75% is a current market rate of interest. 	The nondefault interest rate of the
Millennium Loan is a floating rate of “Wall Street Journal prime” plus 1%. 	The Court takes
judicial notice of the fact that on January 29, 2014, the published Wall Street Journal prime rate
was 3.25%, so the note rate was 4.25%. The nondefault rate on the SBA Loan was 5.567%.
The Bank offered no contrary evidence, instead conceding that it had no substantial
concern about the proposed interest rate. 	Based on the available evidence, the Court finds that
the proposed 4.75% interest rate satisfies § 1129(b)(2)(A)(i)(II).
The proposed repayment term also must also be within market parameters. See, e.g., In
re Wise, 2013 WL 2421984, at *5 (Bankr. D.S.C. 2013), citing 8 Collier on Bankruptcy ¶
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1225.03[4][b][i] (16 th ed. 2010). 	Debtor’s proposed 30-year term is reasonably consistent with
the loan terms when they were originated (24 years for the Bank loan and 20 years for the SBA
loan).5 Furthermore, the Bank again conceded that the repayment term did not stand in the way
of confirmation. The Court finds that the repayment term complies with § 1129(b)(2)(A)(i)(II).
Finally, the Debtor must show that the proposed treatment does not “discriminate
unfairly.” § 1129(b)(2). There are no other substantial secured creditors. 6 The Plan proposes to
pay the Bank’s claims in full over time, with interest. The Plan also requires the maintenance of
the Bank’s collateral and the preservation of the franchise agreement. 	It is likely (there is no
evidence in the record) that the Bank purchased the SBA Claim at a substantial discount. If so,
payment of 100% of the SBA Loan would be a significant economic benefit to the Bank.
Overall, the Debtor’s evidence strongly supports a finding that the Plan does not discriminate
unfairly against the Bank.
Based on this evidence, the burden shifts to the Bank to demonstrate that the Plain
discriminates unfairly. 	See In re Freymiller Trucking, Inc., 190 B.R. 913, 916 (Bankr. W.D.
Okla. 1996) (after prima facie showing of fair treatment, burden shifts to the creditor to
demonstrate discrimination or inequity). The Bank provided no such evidence.
The Court concludes that the Plan satisfies the “cramdown” requirements of § 1129(b).
D. 	§ 1129(a)(11) (“Feasibility”).
The Bank fought Plan confirmation solely on feasibility grounds. 	Section 1129(a)(11)
5 See the documents attached to the Bank’s proofs of claim.
6 TRD has a small secured claim (about $10,325). 	Curry County, New Mexico had a $32,577
property tax claim secured by a first lien on the Hotel real estate, but the claim was paid post-
petition.
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provides that a plan may only be confirmed if it “is not likely to be followed by the liquidation,
or the need for further financial reorganization, of the debtor . . . .” 	The Bank argued in its
objection and at the confirmation hearing that the Plan is not feasible.
“Feasibility is the shorthand term for the requirement of confirmation as set forth in §
1129(a)(11) . . . .” Inv. Co. of the Sw., 341 B.R. at 310. The “Debtor bears the burden to show
feasibility by a preponderance of the evidence.” Id.
“The purpose of section 1129(a)(11) is to prevent confirmation of visionary schemes
which promises [sic] creditors and equity security holders more under a proposed plan than the
debtor can possibly attain after confirmation.” In re Pikes Peak Water Co., 779 F.2d 1456, 1460
(10th Cir. 1985), citing In re Pizza of Hawaii, Inc., 761 F.2d 1374, 1382 (9 th Cir. 1985). 	“In
determining whether a plan is feasible, the bankruptcy court has an obligation to scrutinize the
plan carefully to determine whether it offers a reasonable prospect of success and is workable.”
Id., citing in re Monnier Bros., 755 F.2d 1336, 1342 (8th Cir. 1984). 	See also In re Baker, 302
B.R. 112, at *2 (10th Cir. BAP 2003) (plan is feasible if it “offers a reasonable prospect of
success and is workable”). 	A debtor need not prove to a certainty that it plan will succeed.
Baker, 302 B.R. 112, at *2. 	Rather, a debtor need only support its plan with “projections that
have some basis in fact and experience.” Id. at *3, citing In re Snider Farms, Inc., 83 B.R. 1003,
1012 (Bankr. N.D. Ind. 1988).
“Feasibility determinations must be firmly rooted in predictions based on objective fact.”
Inv. Co. of the Sw, 341 B.R. at 310, citing In re Danny Thomas Props. II Ltd. P’ship, 241 F.3d
959, 964 (8th Cir. 2001).
The Debtor’s evidence supporting feasibility consists of the Cash Flow Projection; the
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testimony of Ms. Kaur; the testimony of Ms. Amandi Dhillon (HMS’s Vice President); and the
Marketing Plan.
Ms. Kaur assisted in preparing the cash flow projections attached to the Debtor’s
Amended Disclosure Statement as Exhibit B (pages 2-5). 	The projections show stable revenue
($1,361,350 per year, which includes gross receipts tax and lodger’s tax receipts) and operating
expenses ($1,101,333.47 per year, which includes gross receipts tax and lodger’s tax payments).
The projected revenue figure is slightly less than the 2013 actual revenue figure shown in the
Marketing Plan7 . The operating expense projections are based on historical expenses and appear
reasonable. The Debtor’s cash flow projection shows a slow erosion in the Debtor’s current cash
balance of $133,759 over five years.
Ms. Kaur testified that the projections were conservative, and that she believed the
Debtor would have more than enough money to make the Plan payments.
HMS has managed the Hotel for the last three years. HMS was retained initially because
the Debtor was not in compliance with its franchise agreement. Since taking over management
duties, the Hotel has been in compliance with the franchise agreement.
Ms. Dhillon prepared the Marketing Plan, which contains revenue information about the
Hotel 	for 	2011-2103. 	The 	Hotel’s 	revenues 	increased 	from 	$1,125,831.42 	in 	2011 	to
$1,229,518.88 in 2013, a 9.2% increase. 	During that time the occupancy rate held steady at
about 72.4%.
The Marketing Plan also contains data comparing the occupancy rate and average daily
7 The revenue in the Marketing Plan does not include New Mexico Gross Receipts Tax or
Lodger’s tax, which total 12.8%.
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rate of the Hotel to its competitors. 	It shows that the Hotel’s occupancy rate lags the
competitor’s average rate of 74.5%. 	The Marketing Plan states that the Hotel’s average daily
rate is $84.97, while the average daily rate of the competition is $89.14.
The Debtor’s strategy is to increase its average daily rate to that of the competition (about
a 5% increase), while keeping occupancy steady. 	The data show that since 2011 the Debtor’s
average daily rate increased from $76.60 to $84.50, or 10%. 	Based on this and the other
testimony of Ms. Dhillon, the Court finds that a further increase of 5% is reasonable.
Several adjustments should be made to the Cash Flow Projection. 	First, the operating
expense deductions for gross receipts tax, lodger’s tax, and franchise fees need to be reduced
because there is an error in the method of their calculation.8
Second, as discussed above it is reasonable to increase the projected income by 5%,
consistent with Ms. Dhillon’s and M.s Kaur’s testimony.
Third, the monthly payment to TRD should be increased from $2,894.23 to $4,082.08.
Finally, the monthly payment to the Bank should be increased from $11,476.24 to
$11,704.29.
A cash flow projection with the adjustments outlined above is attached hereto as Exhibit
A. 9 The Court believes that the revised cash flow projection is a reasonable estimate of future
8 The Cash Flow Projection includes the taxes in the monthly income, and deducts the taxes as
operating expenses. 	The tax deduction amount calculated is a flat percentage of the gross
income, which results in a “tax on tax” error. 	For example, if the monthly gross revenue was
$100,000, $88,642.66 of that amount would be guest receipts, while $11,357.34 would be taxes.
Under the Debtor’s formula, $12,812.50 was the calculated tax figure, an overstatement of
$1,462.50. 	Further, the Debtor calculated franchise fees as a percentage of total gross revenue,
when it should have been based on the hotel guest receipts only.
9 The other figures in the revised projection are taken from the Cash Flow Projection.
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income, expense, and Plan payments. 	The revised projection shows that the Debtor would be
able to fund the Plan obligations.
Further, the Debtor has some flexibility in its expenses. This includes the following:
 	The projection includes a monthly payment to Ms. Kaur of $4,500. While
her family needs the money, and the monthly payment is modest and reasonable, the Court
believes she could and would delay or forego one or more monthly payments if she necessary to
avoid default;
 	The Kaur family now lives in California. 	If necessary to conserve
resources, they likely could move to Clovis, live in the Hotel, and take over the duties of the on-
site manager;
 	The franchise fee is based in part on revenue, so if revenues decrease, the
franchise fee expense (an average of $19,285 per month) would decrease somewhat;
 	Some other expenses vary based on occupancy (e.g. utilities) so a decrease
in revenue would cause a decrease in utility expense; and
 	There is flexibility in the timing of some of the projected expense
payments. For example, the line items for supplies ($9,000 per month), repairs and maintenance
($2,000 per month), and improvements (between $3,024 and $4,500 per month) likely could be
adjusted for a month or two if needed to avoid default.
The Bank’s evidence in support its feasibility objection was limited to cross-examining
Ms. Kaur and Ms. Dhillon. 	The resulting testimony was that there likely would not be much
excess cash, so any unexpected significant downturn in revenue or increase in expenses could
jeopardize the Plan. The witnesses admitted this was so. The Court agrees; there is no question
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that the Plan is not risk-free. 	Nevertheless, overall the Court concludes that the Debtor has
carried its burden to showing that the Plan “offers a reasonable prospect of success and is
workable.” 	Pike’s Peak, 779 F.2d at 1460. 	The Plan is supported by “projections that have
some basis in fact and experience.” 	Baker, 302 B.R. 112, at *3. 	After reviewing the evidence
the Court finds that the Debtor has met its burden demonstrating compliance with § 1129(a)(11).
IV. 	The Motion to Dismiss is Denied.
The Motion to Dismiss was premised on the argument that the Debtor could not confirm
a plan. In light of the Court’s ruling on this issue, the argument is not well taken and should be
overruled. The Motion to Dismiss will be denied.
V. 	Conclusion
There is no guarantee the Debtor it will be able to complete its Plan payments, but the
Debtor presented enough evidence and projections based in fact and experience that the Plan has
a reasonable likelihood of success. In the past several years the Debtor has been able to stabilize
its business and increase revenue, while holding expenses steady. There appears to be room for
growth that is not included in the Debtor’s conservative Cash Flow Projection. Finding that all
of the elements of 1129(a) and (b) are satisfied, the Court will confirm the Plan. 	Debtor’s
counsel is instructed to submit a form of confirmation order to the Court, reflecting the approval
of the Bank’s and UST’s counsel as to form. The Court will prepare and enter a separate order
denying the Motion to Dismiss.
_______________________________________
Hon. David T. Thuma
United States Bankruptcy Judge
Entered on Docket: February 7, 2014.
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Copies to:
R. Trey Arvizu, III
P.O. Box 1479
Las Cruces, NM 88004-1479
Wesley O. Pool
201 Innsdale Terrace
Clovis, NM 88101
Alice N. Page
U.S. Trustee’s Office
P.O. Box 608
Albuquerque, NM 87103-0608
James C. Jacobsen
111 Lomas NW, Ste. 300
Albuquerque, NM 87102-2368
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Revised Cash Flow Projection
1
2
3
4
5
6
7
8
A 	B 	C 	D 	E 	F 	G
January‐14 	February‐14 	March‐14 	April‐14 	May‐14 	June‐14
Cash Balance 	130,000 	124,558 	119,116 	123,612 	132,919 	149,708
Income ‐ Net of Taxes 	93,818 	93,818 	106,802 	113,085 	122,858 	127,977
Oper. Exp.‐Net of Taxes 	73,147 	73,147 	76,193 	77,665 	79,956 	81,157
Plan Payments 	26,113 	26,113 	26,113 	26,113 	26,113 	26,113
Total Payments 	99,260 	99,260 	102,306 	103,778 	106,069 	107,270
Profit (Loss) 	(5,442) 	(5,442) 	4,496 	9,307 	16,789 	20,707
Cash Balance 	124,558 	119,116 	123,612 	132,919 	149,708 	170,415
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Revised Cash Flow Projection
1
2
3
4
5
6
7
8
A
Cash Balance
Income ‐ Net of Taxes
Oper. Exp.‐Net of Taxes
Plan Payments
Total Payments
Profit (Loss)
Cash Balance
H 	I 	J 	K 	L 	M 	N
July‐14 	August‐14 	September‐14 	October‐14 	November‐14 	December‐14
2014 Year
End Totals
170,415 	200,030 	194,588 	189,146 	183,704 	178,262 	172,820
139,611 	93,818 	93,818 	93,818 	93,818 	93,818 	1,267,059
83,883 	73,147 	73,147 	73,147 	73,147 	73,147 	910,883
26,113 	26,113 	26,113 	26,113 	26,113 	26,113 	313,356
109,996 	99,260 	99,260 	99,260 	99,260 	99,260 	1,224,239
29,615 	(5,442) 	(5,442) 	(5,442) 	(5,442) 	(5,442) 	42,820
200,030 	194,588 	189,146 	183,704 	178,262 	172,820 	129,487
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Revised Cash Flow Projection
1
2
3
4
5
6
7
8
A
Cash Balance
Income ‐ Net of Taxes
Oper. Exp.‐Net of Taxes
Plan Payments
Total Payments
Profit (Loss)
Cash Balance
O 	P 	Q 	R 	S 	T 	U
January‐15 	February‐15 	March‐15 	April‐15 	May‐15 	June‐15 	July‐15
129,487 	124,045 	118,603 	123,099 	132,406 	149,195 	169,902
93,818 	93,818 	106,802 	113,085 	122,858 	127,977 	127,977
73,147 	73,147 	76,193 	77,665 	79,956 	81,157 	81,157
26,113 	26,113 	26,113 	26,113 	26,113 	26,113 	26,113
99,260 	99,260 	102,306 	103,778 	106,069 	107,270 	107,270
(5,442) 	(5,442) 	4,496 	9,307 	16,789 	20,707 	20,707
124,045 	118,603 	123,099 	132,406 	149,195 	169,902 	190,609
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Revised Cash Flow Projection
1
2
3
4
5
6
7
8
A
Cash Balance
Income ‐ Net of Taxes
Oper. Exp.‐Net of Taxes
Plan Payments
Total Payments
Profit (Loss)
Cash Balance
V 	W 	X 	Y 	Z 	AA
August‐15 	September‐15 	October‐15 	November‐15 	December‐15
2015 Year
End Totals
190,609 	195,105 	189,663 	184,221 	178,779 	173,337
106,802 	93,818 	93,818 	93,818 	93,818 	1,268,409
76,193 	73,147 	73,147 	73,147 	73,147 	911,203
26,113 	26,113 	26,113 	26,113 	26,113 	313,356
102,306 	99,260 	99,260 	99,260 	99,260 	1,224,559
4,496 	(5,442) 	(5,442) 	(5,442) 	(5,442) 	43,850
195,105 	189,663 	184,221 	178,779 	173,337 	173,337
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Revised Cash Flow Projection
1
2
3
4
5
6
7
8
A
Cash Balance
Income ‐ Net of Taxes
Oper. Exp.‐Net of Taxes
Plan Payments
Total Payments
Profit (Loss)
Cash Balance
AB 	AC 	AD 	AE 	AF 	AG 	AH
January‐16 	February‐16 March‐16 	April‐16 	May‐16 	June‐16 	July‐16
173,337 	167,895 	162,453 	166,949 	176,256 	193,045 	213,752
93,818 	93,818 	106,802 	113,085 	122,858 	127,977 	139,611
73,147 	73,147 	76,193 	77,665 	79,956 	81,157 	83,883
26,113 	26,113 	26,113 	26,113 	26,113 	26,113 	26,113
99,260 	99,260 	102,306 	103,778 	106,069 	107,270 	109,996
(5,442) 	(5,442) 	4,496 	9,307 	16,789 	20,707 	29,615
167,895 	162,453 	166,949 	176,256 	193,045 	213,752 	243,367
Case 12-13786-t11 Doc 108 Filed 02/07/14 Entered 02/07/14 15:30:02 Page 18 of 21

Revised Cash Flow Projection
1
2
3
4
5
6
7
8
A
Cash Balance
Income ‐ Net of Taxes
Oper. Exp.‐Net of Taxes
Plan Payments
Total Payments
Profit (Loss)
Cash Balance
AI 	AJ 	AK 	AL 	AM 	AN
August‐16 	September‐16 	October‐16 	November‐16 	December‐16
2016 Year
End Totals
243,367 	237,925 	232,483 	227,041 	221,599 	216,157
93,818 	93,818 	93,818 	93,818 	93,818 	1,267,059
73,147 	73,147 	73,147 	73,147 	73,147 	910,883
26,113 	26,113 	26,113 	26,113 	26,113 	313,356
99,260 	99,260 	99,260 	99,260 	99,260 	1,224,239
(5,442) 	(5,442) 	(5,442) 	(5,442) 	(5,442) 	42,820
237,925 	232,483 	227,041 	221,599 	216,157 	216,157
Case 12-13786-t11 Doc 108 Filed 02/07/14 Entered 02/07/14 15:30:02 Page 19 of 21

Revised Cash Flow Projection
1
2
3
4
5
6
7
8
A
Cash Balance
Income ‐ Net of Taxes
Oper. Exp.‐Net of Taxes
Plan Payments
Total Payments
Profit (Loss)
Cash Balance
AO 	AP 	AQ 	AR 	AS 	AT 	AU 	AV
January‐17 	February‐17 March‐17 	April‐17 	May‐17 	June‐17 	July‐17 	August‐17
216,157 	210,715 	205,273 	209,769 	219,076 	235,865 	256,572 	277,279
93,818 	93,818 	106,802 	113,085 	122,858 	127,977 	127,977 	106,802
73,147 	73,147 	76,193 	77,665 	79,956 	81,157 	81,157 	76,193
26,113 	26,113 	26,113 	26,113 	26,113 	26,113 	26,113 	26,113
99,260 	99,260 	102,306 	103,778 	106,069 	107,270 	107,270 	102,306
(5,442) 	(5,442) 	4,496 	9,307 	16,789 	20,707 	20,707 	4,496
210,715 	205,273 	209,769 	219,076 	235,865 	256,572 	277,279 	281,775
Case 12-13786-t11 Doc 108 Filed 02/07/14 Entered 02/07/14 15:30:02 Page 20 of 21

Revised Cash Flow Projection
1
2
3
4
5
6
7
8
A
Cash Balance
Income ‐ Net of Taxes
Oper. Exp.‐Net of Taxes
Plan Payments
Total Payments
Profit (Loss)
Cash Balance
AW 	AX 	AY 	AZ 	BA
September‐17 	October‐17 	November‐17 	December‐17
2017 Year
End Totals
281,775 	281,775 	277,521 	273,267 	269,013
93,818 	93,818 	93,818 	93,818 	1,268,409
73,147 	73,147 	73,147 	73,147 	911,203
26,113 	24,925 	24,925 	24,925 	309,792
99,260 	98,072 	98,072 	98,072 	1,220,995
(5,442) 	(4,254) 	(4,254) 	(4,254) 	47,414
281,775 	277,521 	273,267 	269,013 	269,013
Case 12-13786-t11 Doc 108 Filed 02/07/14 Entered 02/07/14 15:30:02 Page 21 of 21