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Memorandum of Law in Support of Motion for Relief from the Automatic Stay Filed by

Date
2018-07-06

Full text

IN THE UNITED STATES BANKRUPTCY COURT
FOR THE NORTHERN DISTRICT OF WEST VIRGINIA

In re:

PANTHERA ENTERPRISES, LLC,

Debtor

Aaron C. Amore, Chapter 7 Trustee

_____________________________________

WEST VIRGINIA ECONOMIC
DEVELOPMENT AUTHORITY,
                                                 Movant,

v.

PANTHERA ENTERPRISES, LLC
                                                  Respondent.

      BK No. 2:19-bk-00787

      Chapter 7

LIST OF EXHIBITS

Memorandum of Law in Support of Motion for Relief from the Automatic Stay Filed by
the West Virginia Economic Development Authority

Exhibit A
Forbearance Agreement dated July 6, 2018 by and among the West
Virginia Economic Development Authority, Panthera Enterprises,
LLC, Global Matrix Corporation, Pons Milvius LLC, James V.
Punelli, Raymond C. Jones and Panthera Training, LLC

Exhibit B
Credit Line Deed of Trust and Fixture Filing executed by the Debtor
for the benefit of the WVEDA, dated August 21, 2013; and Credit
Line Deed of Trust and Fixture Filing executed by the Debtor for the
benefit of the WVEDA, dated July 2, 2014

Exhibit C
Bill of Sale, dated June 15, 2018, given by James Punelli, Raymond
Jones, TenX Group LLC, Panthera Training Center, LLC and
Panthera Worldwide LLC, to SMI LLC

Exhibit D
Contract of Sale, dated July 23, 2015 executed by TenX Group LLC
and Bill V. Neff, Sr.

No. 2:19-bk-00787    Doc 346-1    Filed 05/21/21    Entered 05/21/21 10:00:23    Page 1
of 2

Exhibit E
Declaration of Robert L. Starer, dated May 19, 2021

Exhibit A1 through A4
Pictures

Exhibit B
Aerial Photograph of Modular
Buildings, taken from Contract of Sale

Exhibit C1 and C2
Pictures

Exhibit D1 through D3
Pictures

Exhibit E1 through E3
Pictures

Exhibit F1 through F3
Pictures

Exhibit G1 and G2
Pictures

No. 2:19-bk-00787    Doc 346-1    Filed 05/21/21    Entered 05/21/21 10:00:23    Page 2
of 2

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