WVEDA's Motion to Convert or Dismiss

Summary

A List of Exhibits to WVEDA's Motion to Convert or Dismiss in In re Panthera Enterprises, LLC, BK No. 2:19-bk-00787, Chapter 11, U.S. Bankruptcy Court for the Northern District of West Virginia, filed as Doc 52-1 on November 2, 2019. West Virginia Economic Development Authority is the movant and Panthera Enterprises, LLC is the respondent. Exhibit A is the Authority's Proof of Claim, filed October 23, 2019, with sub-exhibits that include a Promissory Note for $5,000,000 dated August 21, 2013 and a Promissory Note for $1,871,505 dated July 2, 2014. Exhibit B is a transcript of Mr. James Punelli's testimony at the first meeting of creditors, October 18, 2019, and Exhibit I is a Complaint, Civil Action No. 18-cv-1028, in the United States District Court for the Middle District of North Carolina.

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

In re:

PANTHERA ENTERPRISES, LLC,

Debtor

      BK No. 2:19-bk-00787

      Chapter 11

WEST VIRGINIA ECONOMIC
DEVELOPMENT AUTHORITY,

Movant

v.

PANTHERA ENTERPRISES, LLC,

Respondent

LIST OF EXHIBITS
WVEDA's Motion to Convert or Dismiss

Exhibit A  . . . . . . . . West Virginia Economic Development Authority's
Proof of Claim, filed October 23, 2019

Exhibit A-1  . . .  Loan Agreement date August 21, 2013

Exhibit A-2  . . . Promissory Note, $5,000,000, dated August 21, 2013

Exhibit A-3  . . . Credit Line Deed of Trust and Fixture Filing (recorded), dated August
21, 2013

Exhibit A-4  . . . Collateral Assignment of Leases and Rents (recorded), effective
August 21, 2013

Exhibit A-5  . . . Loan Agreement dated July 2, 2014

Exhibit A-6  . . . Promissory Note, $1,871,505, dated July 2, 2014

Exhibit A-7  . . . Credit Line Deed of Trust and Fixture Filing (recorded), dated July 2,
2014

Exhibit A-8  . . . Collateral Assignment of Leases and Rents (recorded), effective July 2,
2014

Exhibit A-9  . . . Forbearance Agreement date July 6, 2018
Exhibit B . . . . . . . .  Transcript of Mr. James Punelli's testimony at the first meeting of
creditors, October 18, 2019
Exhibit C . . . . . . . .
Affidavit of Robert L. Starer

Exhibit C-1 . . .
Commercial Lease Agreement dated June 1, 2018 between the Debtor
and Panthera Training, LLC

Exhibit C-2 . . .
Agreement of assignment, effective as of June 1, 2018, by the Debtor
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and Panthera Training Center, LLC, to Panthera Training, LLC

Exhibit C-3 . . .  Subcontract, effective June 1, 2018, between the Debtor, Panthera
Worldwide LLC and Panthera Training Center, LLC, with Panthera
Training, LLC

Exhibit C-4 . . .  Wire memos to the accounts of Raymond Jones and Punelli Partner
Limited Company

Exhibit C-5 . . .  Subordination, Non-Disturbance and Attornment Agreement between
West Virginia Economic Development Authority and Panthera
Training, LLC, dated November 1, 2018

Exhibit C-6 . . .  Income sources with list of "current customers" provided by Punelli
and Jones in May 2018

Exhibit C-7 . . .  Bill of Sale, dated June 15, 2018

Exhibit C-8 . . .
Amended Promissory Note dated June 16, 2016, given to SMI, LLC
and Security Agreement dated September 23, 2015
Exhibit D . . . . . . . .  Commercial Lease dated August 1, 2013 between the Debtor and
Panthera Training Center, LLC
Exhibit E . . . . . . . .  Affidavit of J. Steven Webb, WVEDA

Exhibit E-1 . . .
Loan Histories, WVEDA

Exhibit E-2 . . .
Notice of Default and Demand for Payment, dated August 14, 2019
Exhibit F . . . . . . . .
Recorded Memorandum of Timber Agreement and Timber Agreement,
dated March 26, 2018
Exhibit G . . . . . . . .  Affidavit of William White

Exhibit G-1 . . .
Summary of projected versus actual customer and income, 2018,
prepared by William White
Exhibit H . . . . . . . .
Payments to Punelli and Jones by PTC
Exhibit I  . . . . . . . .  Complaint, Civil Action No. 18-cv-1028, United States District Court
for the Middle District of North Carolina

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