Source document (2020-06-08)

Summary

Panthera Training, LLC filed this supplemental evidence on 06/08/20 as Doc 162 in BK No. 2:19-BK-00787 in the Bankruptcy Court for the Northern District of West Virginia, supporting its joint motion with the West Virginia Economic Development Authority to convert the Panthera Enterprises, LLC Chapter 11 case to Chapter 7. It relies on subpoenaed Atlantic Union Bank records of the debtor's non-debtor subsidiary, Panthera Training Center, LLC. The filing says the debtor received $172,000 from the DEA on October 21, 2019 and the same day wired $134,160.00 to the subsidiary's new account, later calling the transfer an error. It alleges that through March 2020 over $102,000 went to the debtor's principals, James Punelli and Raymond Jones, and to Punelli's family partnership.

Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used

Full text

Text recognized from a scanned document; may contain errors. Pages 10–12, 17, 20, 30, and 31 of 31 are not shown because the text could not be recognized reliably.

No. 2:19-bk-00787 Doc162 Filed 06/08/20 Entered 06/08/20 11:55:42 Page 1 of
31

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

In re
PANTHERA ENTERPRISES, LLC, : BK No. 2:19-BK-00787

Debtor. : Chapter 11

PANTHERA TRAINING, LLC, and
WEST VIRGINIA ECONOMIC
DEVELOPMENT AUTHORITY,
Movants,
PANTHERA ENTERPRISES, LLC,
Respondent.
PANTHERA TRAINING, LLC'S SUPPLEMENTAL EVIDENCE

IN SUPPORT OF JOINT MOTION TO CONVERT THIS CASE TO A
CHAPTER 7 PROCEEDING FOR CAUSE PURSUANT TO 11 U.S.C. § 1112(b)(1)

Panthera Training, LLC ("Panthera Training"), by counsel, submits the following
supplemental evidence in support of the Joint Motion to Convert this Case to a Chapter 7
Proceeding for Cause Pursuant to 11 U.S.C. § 1112(b)(1) ("Joint Motion") filed by Panthera
Training and the West Virginia Economic Development Authority:

1, The Joint Motion seeks to have this bankruptcy case converted to a
Chapter 7 proceeding with the appointment of a Chapter 7 Trustee for cause pursuant to §
1112(b)(1) of the Bankruptcy Code. The Movants assert cause exists based upon (a) gross
mismanagement of the bankruptcy estate; (b) failure to maintain appropriate insurance; and (c)
continuing loss and diminution of the estate and the absence of a reasonable likelihood of

rehabilitation. 11 U.S.C. § 1112(b(4)(A) - (C).
No. 2:19-bk-00787 Doc162 Filed 06/08/20 Entered 06/08/20 11:55:42 Page 2 of
31 |

2. Gross mismanagement of the bankruptcy estate is largely based upon the
Debtor's failure to prepare and file complete and accurate operating reports (“the Operating
Reports”). In their Joint Motion, the Movants reviewed relevant entries from the Operating
Reports filed from September 2019 through March 2020’ in order to highlight how the Debtor;
(i) transferred the Debtor’s funds to its non-debtor subsidiary, Panthera Training Center, LLC
("Center"), claiming it was done in error, but not fully returning the funds to the Debtor until
four (4) months later; and (ii) used the Debtor's funds to pay Center's payable owed to Panthera
Training instead of paying those payables with Center's funds, and then falsely reported the
payments as being made on one of Debtor's contract’s payables. Doc 132, pp. 4-10.

3. In its Objection to the Joint Motion, the Debtor took umbrage with the
allegations that it "filed false operating reports, implying some intent by the Debtor to mislead or
otherwise mischaracterize the payments at issue." Doc 147, p. 5. The Debtor submitted "the few
alleged inaccuracies on the Monthly Operating Reports were inadvertent . . . " and passed the
"errors" off as "understandable human frailty." Jd.

4. However, Center's recently received bank account records reveal the truth.

5. At the end of last week, Panthera Training received records for Center's
bank account with Atlantic Union Bank in response to a document subpoena. The subpoena was
served in a breach of contract lawsuit pending in the Circuit Court of Loudoun County, Virginia,
styled Panthera Training, LLC v. Panthera Training Center, LLC, CL200002269-00, in which
Panthera Training is seeking judgment of $91,894.60 owed to it by Center. See Center's bank
records ("Bank Records") attached to the Affidavit of Douglas E. Kahle, Esq., attached to this

Supplement as Exhibit A.

' The Debtor is delinquent, and has not yet filed its April, 2020 Operating Report.
No. 2:19-bk-00787 Doc162 Filed 06/08/20 Entered 06/08/20 11:55:42 Page 3 of
31

6. As the transactions between the Debtor and Center are reviewed below, it
should be kept in mind that the Bank Records disclose that Debtor's responsible party, James
Punelli (“Punelli”’), is also the sole authorized signatory on Center's bank account. Ex. A, p. PT
21.

7. In its September Operating Report, the Debtor reported a receivable of
$177,883.00 was expected in October, 2019 from the DEA in payment of a training class. Doc
37, p. 10. This is a training class that Panthera Training conducted for the DEA under Panthera
Training's Subcontract with the Debtor. See Doc 132, {§ 5-6. Also in its September Operating
Report, in order to establish a foundation for the subsequent transfer of funds to Center, the
Debtor created a fictitious payable owed to Center. Doc 37, p. 9.

8. In order to receive the funds that were about to be transferred from the
Debtor to Center, on October 4, 2019 Mr. Punelli opened a new bank account for Center with
Atlantic Union Bank, with a deposit of $1,000.00. Ex. A, p. PT 6.

9. On October 21, 2019, the Debtor received the $172,000 that was expected
from the DEA. Doc 63, p. 16. On the very same day the Debtor wired $134,160.00 to Center's
new bank account. Doc 63, p. 8; Ex.A, p. PT 6.

10. In the same report that reflected the transfer of funds, the Debtor
characterized the transfer of the $134,160 to Center as an "error," but instead of immediately
returning the money, the Debtor stated that the money would be "refunded and shown on the
November operating report." Doc 63, p. 8. The Debtor's November Operating Report, however,
later represented that there had been a "miscommunication” such that the $134,160 was not

refunded during November. Doc 80, p. 6.
No. 2:19-bk-00787 Doc162 Filed 06/08/20 Entered 06/08/20 11:55:42 Page 4 of
31

11. As addressed previously, payments by the DEA for the training conducted
by Panthera Training were supposed to have been forwarded immediately to Panthera Training.
See Doc 52-7, p. 26. But the $172,000 was not paid to Panthera Training. Instead, the Debtor
moved $134,160.00 to Center’s non-debtor bank account where the use of the Debtor's funds
would be outside the purview of this Bankruptcy Court and the Debtor's creditors.

12. Center's Bank Records show on the same day that the $134,160.00 was
transferred to Center's bank account, $8,100 was transferred from Center’s bank account to
Panthera Worldwide, LLC, a “non-operational” subsidiary of the Debtor, also managed by
Punelli along with Raymond Jones. Doc 52-5 (341 Transcript, pp. 15:1-6; 27:15-17; 29:4-6; and
75: 13-17.). This transfer was followed by a series of distributions, beginning later in October,
being made to Punelli, his family partnership, and to Raymond Jones, the Debtor’s other
principal. Ex. A, pp PT 7-18, 20.

13. In the weeks and months that followed the Debtor’s transfer of $134,160
to Center, continuing through March, 2020, altogether over $102,000 was siphoned off to the
principals of the Debtor; Punelli and Raymond Jones, and to Punelli’s family partnership. Ex. A,
pp PT 7-18. It is highly likely, although not expressly stated on the face of the Bank Records,
that most of the other disbursements from Center’s bank account with unidentified beneficiaries,
such as the purchase of a $2,861.53 airline ticket with Iceland Air, were also for Punelli’s

personal benefit. Ex. A, p PT 15.

* Given the multiple distributions from Center’s account to the Debtor’s principals addressed
above, one may wonder how Center eventually returned the $134,160 to the Debtor. Doc 93, p.
7; Doc 110, p. 7. The Bank Records answer this question as they show the receipt of payments
of the invoices owed for the SOCOM and 1“ CIG training conducted by Panthera Training, but
not paid by Center, as addressed in the Joint Motion. Ex. A, pp PT 12, 15, 16 and 17.
No. 2:19-bk-00787 Doc162 Filed 06/08/20 Entered 06/08/20 11:55:42 Page 5 of
31

14. ‘The timing of the Debtor’s receipt of the DEA payment, the immediate
transfer of $134,160 from that DEA payment to Center’s new bank account, and the subsequent
pattern of distributions of these funds to Mr. Punelli, his family partnership, and Raymond Jones,
compel the irrefutable conclusion that the $134,160 transfer to Center on October 21, 2019 was
anything but an “error” on the part of the Debtor’s responsible party. And, as pointed out in the
Joint Motion, since Mr. Punelli is the responsible person for both the Debtor and Center (Doc
132, n. 2.) it is truly incredible that the Debtor represented that the funds were not returned to the
Debtor in November, 2019 because Punelli “miscommunicated” with himself. Center’s Bank
Records reveal that there was no simple “error”, there was no “miscommunication”, and there
were no “inadvertent” mischaracterizations related to the Debtor’s false entries related to its
financial transactions involving Center. Rather, Center’s Bank Records reveal the existence of a
fraudulent scheme that was devised and employed to free up cash for the Debtor's principals',
and Punelli’s family’s, personal use, outside of the purview of the Bankruptcy Court and the
Debtor’s creditors.

15. | The Debtor's actions and more specifically, the actions of its responsible
party, represent a bold and stunning breach of the fiduciary duty owed to the Debtor’s creditors.
This case cries out for the appointment of a Trustee and conversion to a Chapter 7.

WHEREFORE, Panthera Training, LLC requests that the Court convert this case
to one under Chapter 7 with the appointment of a Chapter 7 Trustee, and grant such further relief
as this cause merits.

PANTHERA TRAINING, LLC

By Counsel

/s/_ Douglas E. Kahle, Esq.
No. 2:19-bk-00787 Doci162 Filed 06/08/20 Entered 06/08/20 11:55:42 Page 6 of
31

Douglas E. Kahle (VA BAR No. 15964)

BASNIGHT, KINSER, LEFTWICH & NUCKOLLS, P.C.
308 Cedar Lakes Drive, 2nd Floor

Chesapeake, Virginia 23322

Telephone: (757) 547-9191

Facsimile: (757) 547-9135

E-mail: |§ DKahle@basnightkinser.com
No. 2:19-bk-00787 Doc162 Filed 06/08/20 Entered 06/08/20 11:55:42 Page 7 of
31

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

In re
BK No. 2:19-bk-00787
PANTHERA ENTERPRISES, LLC,

Chapter 11

Debtor.
WEST VIRGINIA ECONOMIC
DEVELOPMENT AUTHORITY,

Movant,
Vv.
PANTHERA ENTERPRISES, LLC,

Respondent.

CERTIFICATE OF SERVICE

I, Douglas E. Kahle, Esq., hereby certify that on this 8"" day of June 2020, the foregoing
Panthera Training, LLC's Supplemental Evidence in Support of Joint Motion to Convert This
Case to a Chapter 7 Proceeding for Cause Pursuant to 11 U.S.C. § 1112(b)(1) was served

through the Court’s ECF system on all parties registered to receive CM/ECF notices, including:

Mark A. Lindsay Gary O. Kinder

John J. Richardson U.S. Trustee's Office

Robert S. Bernstein 300 Virginia Street East, Rm. 2025
Bernstein-Burkley, P.C. Charleston, WV 25301

707 Grant Street, Ste. 2200 U.S. Trustee

Pittsburgh, PA 15219

Counsel for the Debtor

Debra Lee Allen

Spilman Thomas & Battle, PLLC

c/o 292 Pleasant Valley Drive

Charles Town, WV 25414

Counsel for the West Virginia Economic Development Authority
No. 2:19-bk-00787 Doci162 Filed 06/08/20 Entered 06/08/20 11:55:42 Page 8 of
31

/s/_ Douglas E. Kahle, Esq.

Douglas E. Kahle (VA BAR No. 15964)

BASNIGHT, KINSER, LEFTWICH & NUCKOLLS, P.C.
308 Cedar Lakes Drive, 2nd Floor

Chesapeake, Virginia 23322

Telephone: (757) 547-9191

Facsimile: (757) 547-9135

E-mail: | DKahle@basnightkinser.com
No. 2:19-bk-00787 Doc162 Filed 06/08/20 Entered 06/08/20 11:55:42 Page 9 of
31

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

In re:
PANTHERA ENTERPRISES, LLC Case No. 2:19-BK-787
Chapter 11
Debtor.
AFFIDAVIT OF DOUGLAS E. KAHLE, ESQ.
COMMONWEALTH OF VIRGINIA )
CITY OF CHESAPEAKE )

This day personally appeared before me, a Notary Public in and for the jurisdiction
aforesaid, Douglas E. Kahle, Esq., who, being duly sworn, states as follows;

1. Acting as legal counsel for Panthera Training, LLC (“Training”), I filed a
breach of contract lawsuit against Panthera Training Center, LLC (“PTC”) in the Loudon County
Circuit Court in the Commonwealth of Virginia, styled as Panthera Training, LLC, v. Panthera
Training Center, LLC, CL20-2269. (“the Litigation”).

2. In connection with discovery conducted in the Litigation, I served a

document subpoena (“the Subpoena’) on PTC’s bank, Atlantic Union Bank.
3. Attached hereto are true and accurate copies of documents received from
Atlantic Union Bank pursuant to the Subpoena.
Further the Affiant saith not.

Douglas E. Kahle, Esq.
Taken, subscribed and sworn to before me this 8" day of June, 2020.

My commission expires: 4 la0 [ a2.

Registration number: \471 9 | A ely K Brel

NOTARY PUBLIC

|

BECIY G, BRINN

NOTARY PUBLIC
COMMONWEALTH OF VIRGINIA
RY COMMISSION EXPIRES SEPTEMBER 30, AQP}

[NOTORIAL SEAL]

EXHIBIT
No. 2:19-bk-00787 Doc 162 Filed 06/08/20 Entered 06/08/20 11:55:42 Page 13 of

June 3, 2020

DOUGLAS E KAHLE
308 CEDAR LAKES DRIVE, 28° FLOOR
CHESAPEAKE, VA 23322

Re: PANTHERA TRAINING

Dear Douglas Kahle, Esquire

In response to the legal document requesting client records, issued for the past 7 months in the above
mentioned matters, | have enclosed the requested documents. These documents consist of statements,
checks, deposits, wires, resolution and signature cards. The time frame for these records is September
01, 2019 — May 31, 2020.

Our Bill for services rendered in complying with this Subpoena for Records is enclosed. Please forward
your check in the amount of $50.00 within thirty (30) days of receipt of this letter, payable to Atlantic
Union Bank, to the attention of William Vaughan, Centralized Fulfillment Services.

If you have any questions or concerns relative to our response, please contact me at the numbers listed
below.

Sincerely,

William Vaughan

Centralized Fulfillment Services

Atlantic Union Bank

PO Box 940

Ruther Glen, VA 22546

P 804-448-0751 Team Line 804-589-3065 Fax 804-633-5275
william.vaughan@atlanticunionbank.com

BATES-PT- 004
No. 2:19-bk-00787 Doc162 Filed 06/08/20 Entered 06/08/20 11:55:42 Page 14 of
31

DECLARATION OF ATLANTIC UNION BANK CERTIFYING RECORDS
OF REGULARLY CONDUCTED BUSINESS ACTIVITY

|, the undersigned, William Vaughan, declare:

1. |am employed by Atlantic Union Bank as a Centralized Fulfillment Representative, and by
reason of my position am authorized and qualified to make this declaration.
2. | further certify that the enclosed documents including statements, checks, deposits, and
signature card are true copies of records that were:
a. Made at or near the time of the occurrence of the matters set forth therein, by, or from
information transmitted by, a person with knowledge of those matters;
b. Kept in the course of regularly conducted business activity; and
Made by the regularly conducted business activity as a regular practice.

| declare under penalty of perjury that the foregoing is true and correct. Executed on June 03, 2020.

PANTHERA TRAINING

BATES-PT- 005
No. 2:19-bk-00787 Doc162_ Filed 06/08/20

31
#4 Union Bank

PANTHERA TRAINING CENTER LLC
215 DEPOT CT SE FL 2
LEESBURG VA 20175-3017

Entered 06/08/20 11:55:42 Page 15 of

STATEMENT SUMMARY AS OF 10/31/19

Account Number

Account Name
SMALL BUSINESS CHECKING

SMALL BUSINESS CHECKING

PANTHERA TRAINING CENTER LLC

Page 1 of 3
Account Number: 44
Date 10/31/19
Images: 1
Balance
126,356.96

Beginning Balance 10/04/19 .00
Deposits / Misc Credits 3 141,432.37
Withdrawals / Misc Debits 13 15,075.41
** Ending Balance 10/31/19 126,356.96 **
Service Charge .00
Average Balance 51,439
Average Collected Balance 51,439
Minimum Balance 783
Enclosures 1
Transaction Detail
Date Activity Description Deposits Withdrawals Balance
10/04 DEPOSIT 1,000.00 1,000.00
10/18 POS PURCHASE Non-PIN 140.83 859.17
LYON COLLECTION SRVCS 800-9355966 NV
IN7200 *****5063 10/17 03:33
10/18 POS PURCHASE Non-PIN 75.24 783.93
LYON COLLECTION SRVCS 800-9355966 NV
IN9000 *****5063 10/17 03:33
10/21 Ref 2940951 from Dep 1080067414 6,272.37 7,056.30
10/21 WIRE/IN ORG: PANTHERA ENTERPRISES LLC 134,160.00 141,216.30
10/21 INCOMING WIRE FEE 15.00 141,201.30
10/21 Ref 2941009 to Dep 1080067414 For PTC pa 8,100.00 133,101.30
yments via wire
10/22 POS PURCHASE Non-PIN 76.00 133,025.30
WV TREASURY BASIC 866-2439010 WV
764095 *****5063 10/21 14:36
10/23 POS PURCHASE Non-PIN 79.99 132,945.31
FS *Readdle 877~3278914 CA 296960
*¥*#*#5063 10/22 21:55
10/23 DE eCorp Tax/E-CHECK 1,165.00 131,780.31
Panthera Training Cent
10/23 DE eCorp Tax/E-CHECK 1,165.00 130,615.31
Panthera Training Cent
10/23 DE eCorp Tax/E-CHECK 1,165.00 129,450.31
Panthera Training LLC
10/23 WVTREASURY/SOS 76.00 129,374.31

James Punelli

BATES-PT- 006
No. 2:19-bk-00787 Doc162 Filed 06/08/20 Entered 06/08/20 11:55:42 Page 16 of

31
Page 2 of 3
PANTHERA TRAINING CENTER LLC Account Number: @aaagB44
Date: 10-31-19
Images: i
Transaction Detail
Date Activity Description Deposits Withdrawals Balance
10/29 POS PURCHASE with PIN 7.35 129,366.96
USPS KIOSK 51510 LEESBURG VA 009550
**#*%*5063 10/29 15:09
10/29 MISCELLANEOUS DEBIT 510.00 128,856.96
2,500.00 126,356.96

10/30 WIRE/OUT BNF: JONES RAYMOND

BATES-PT- 007
No. 2:19-bk-00787 Doc162 Filed 06/08/20 Entered 06/08/20 11:55:42 Page 18 of

31
#4 Union Bank

PANTHERA TRAINING CENTER LLC

215 DEPOT CT SE Fi 2 Page 1 of 3

LEESBURG VA 20175-3017
Account Number: @Q@aRRNRS 44
Date 11/30/19
Images: 1

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STATEMENT SUMMARY AS OF 11/30/19

Account Name Account Number Balance
SMALL BUSINESS CHECKING Ga 44 105,539.17
SMALL BUSINESS CHECKING PANTHERA TRAINING CENTER LLC Acct a 44
Beginning Balance 11/01/19 126,356.96
Deposits / Misc Credits ce) .00
Withdrawals / Misc Debits 22 20,817.79
** Ending Balance 11/30/19 105,539.17 **
Service Charge -00
Average Balance 108,424
Average Collected Balance 108,424
Minimum Balance 105,539
Enclosures 1
Transaction Detail
Date Activity Description Deposits Withdrawals Balance
11/01 WIRE/OUT BNF:PUNELLI PARTNERS LIMITED CO 12,500.00 113,856.96
11/04 POS PURCHASE Non-PIN 198.00 113,658.96

AGENTS AND CORPORATIONS 302-5750877 DE
710041 *****5063 11/03 09:40

11/05 POS PURCHASE Non-PIN 196.88 113,462.08
VBS*VONAGE BUSINESS 866-901-0242 GA
INO800 *****5063 11/04 22:12

11/05 ATLANTIC UNION/BEB FEES 30.00 113,432.08
PANTHERA ENTERPR
11/06 POS PURCHASE Non-PIN 109.60 113,322.48

PALMETTO TECHNOLOGY GR 864-552-1291 Sc
058583 *****5063 11/05 03:48

11/07 CHECK #2470 1,100.00 112,222.48

11/08 WIRE/OUT BNF:JAMES PUNELLI 800.00 111,422.48

11/08 WIRE/OUT BNF: JAMES PUNELLI 589.33 110,833.15

11/08 NC DEPT REVENUE/TAX PYMT 2,114.31 108,718.84
1400310000032469678502

11/12 VA DEPT TAXATION/TAX PAYMEN 10.51 108,708.33
Panthera Solutions, Lh

11/12 VA DEPT TAXATION/TAX PAYMEN 10.51 108,697.82
Panthera Solutions, LL

11/12 VA DEPT TAXATION/TAK PAYMEN 10.51 108,687.31

BATES-PT- 009
No. 2:19-bk-00787 Doc162_ Filed 06/08/20

31

Atlantic
Union Bank

Entered 06/08/20 11:55:42 Page 19 of

Page 2 of 3
PANTHERA TRAINING CENTER LLC Account Number: GED 5:44
Date: 11-30-19
Images: 1
Transaction Detail
Date Activity Description Deposits Withdrawals Balance
Panthera Solutions, LL
11/12 VA DEPT TAXATION/TAX PAYMEN 10.51 108,676.80
Panthera Solutions, LL
11/12 VA DEPT TAXATION/TAX PAYMEN 10.37 108,666.43
Panthera Solutions, LL
11/12 VA DEPT TAXATION/TAX PAYMEN 10.37 108,656.06
Panthera Solutions, LL
11/12 VA DEPT TAXATION/TAX PAYMEN 10.37 108,645.69
Panthera Solutions, LL
11/12 VA DEPT TAXATION/TAX PAYMEN 10.37 108,635.32
Panthera Solutions, LL
11/12 VA DEPT TAXATION/TAX PAYMEN 10.37 108,624.95
Panthera Solutions, LL
11/12 VA DEPT TAXATION/TAXK PAYMEN 10.36 108,614.59
Panthera Solutions, LL
11/12 VA DEPT TAXATION/TAX PAYMEN 5.92 108 ,608.67
Panthera Solutions, LL
11/18 POS PURCHASE Non-PIN 2,950.00 105 ,658.67
USFCR 877-252-2700 HTTPSUSCONTRA FL
INB700 ***#**5063 11/15 22:45
11/18 POS PURCHASE Non-PIN 119.50 105 ,539.17
HARLANDCLARKECHECKPRNT 877-534-3769 TX
INC9O00 *****5063 11/17 22:29
Checks
Date Check No Amount Date Check No Amount Date Check No Amount
11/07 2470 1,100.00

* indicates a break in check number sequence

BATES-PT- 010
No. 2:19-bk-00787 Doc162 Filed 06/08/20 Entered 06/08/20 11:55:42 Page 21 of

31
4 Union Bank
PANTHERA TRAINING CENTER LLC
215 DEPOT CT SE FL 2 Page 1 of 2
LEESBURG VA 20175-3017 Account Number: 44
Date 12/31/19
Images: 0
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STATEMENT SUMMARY AS OF 12/31/19
Account Name Account Number Balance
SMALL BUSINESS CHECKING Gama +: 15,902.07
SMALL BUSINESS CHECKING PANTHERA TRAINING CENTER LLC Acct QS 44
Beginning Balance 12/01/19 105,539.17
Deposits / Misc Credits 1 30,200.00
Withdrawals / Misc Debits 15 119,837.10
** Ending Balance 12/31/19 15,902.07 **
Service Charge .00
Average Balance 45,283
Average Collected Balance 45,283
Minimum Balance 15,902
Transaction Detail
“Date Activity Description Deposits Withdrawals Balance
12/02 WIRE/OUT BNE: PUNELLI PARTNERS LIMITED CO 6,000.00 99,539.17
12/02 WIRE/OUT BNF:JAMES PUNELLI 800.00 98,739.17
12/04 ATLANTIC UNION/BEB FEES 30.00 98,709.17
PANTHERA ENTERPR
12/05 POS PURCHASE Non-PIN 196.88 98,512.29
VBS* VONAGE BUSINESS 866-901-0242 GA
INB600 *****5063 12/04 21:36
12/05 GO DADDY/WEB ORDER 59.96 98,452.33
Punelli
12/06 WIRE/OUT BNF:PANTHERA ENTERPRISES LLC 50,000.00 48,452.33
12/16 DCD/Misc Pay 30,200.00 78,652.33
PANTHERA TRAININ
12/16 WIRE/OUT BNF:PUNELLI PARTNERS LIMITED CO 3,000.00 75,652.33
12/16 WIRE/OUT BNF: JAMES PUNELLI 589.33 75,063.00
12/16 GO DADDY/WEB ORDER 36.34 75,026.66
Punelli
12/18 WIRE/OUT BNF:PANTHERA ENTERPRISES LLC 50,000.00 25,026.66
12/23 WIRE/OUT BNF:LINCOLN AND MORGAN 5,000.00 20,026.66
12/23 WIRE/OUT BNF:PUNELLI PARTNERS LIMITED CO 2,000.00 18,026.66
12/23 WIRE/OUT BNF: JONES RAYMOND 2,000.00 16,026.66
12/23 GO DADDY/WEB ORDER 14.99 16,011.67
Punelli

BATES-PT- 012
No. 2:19-bk-00787 Doc162_ Filed 06/08/20
31

4 Union Bank

Transaction Detail

Entered 06/08/20 11:55:42 Page 22 of

Date Activity Description

Page 2 of 2
PANTHERA TRAINING CENTER LLC Account Number: Gay 44
Date: 12-31-19
Images: 0
Deposits Withdrawals Balance
109.60 15,902.07

12/30 POS PURCHASE Non-PIN
PALMETTO TECHNOLOGY GR 864-436-7189 SC
058583 *****5063 12/27 03:48

BATES-PT- 013
No. 2:19-bk-00787 Doc162_ Filed 06/08/20

PANTHERA TRAINING CENTER LLC

Atlantic
Union Bank

Entered 06/08/20 11:55:42 Page 23 of

215 DEPOT CT SE FL 2 Page 1 of 2
LEESBURG VA 20175-3017 Account Number: 544
Date 01/31/20
Images: 0
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banker or visit AtlanticUnionBank.com to start the new year saving
smartly.
STATEMENT SUMMARY AS OF 01/31/20
Account Name Account Number Interest Paid Balance
In 2019
SMALL BUSINESS CHECKING ay: 00 16,181.10
SMALL BUSINESS CHECKING PANTHERA TRAINING CENTER LLC Acct Ga *4
Beginning Balance 1/01/20 15,902.07
Deposits / Misc Credits 1 22,232.40
Withdrawals / Misc Debits 24 21,953.37
** Ending Balance 1/31/20 16,181.10 **
Service Charge -00
Average Balance 7,479
Average Collected Balance 7,479
Minimum Balance 3,940
Transaction Detail
“Date Activity Description Deposits Withdrawals Balance
1/02 WIRE/OUT BNF:PUNELLI PARTNERS LIMITED CO 8,000.00 7,902.07
1/02 WIRE/OUT BNF:JAMES PUNELLI 800.00 7,102.07
1/06 POS PURCHASE Non~PIN 188.19 6,913.88
VBS*VONAGE BUSINESS 866-901-0242 GA
INC300 *****5063 01/04 21:30
1/06 ATLANTIC UNION/BEB FEES 30.00 6,883.88
PANTHERA ENTERPR
1/07 POS PURCHASE Non-PIN 278.35 6,605.53
PALMETTO TECHNOLOGY GR 864-436-7189 SC
058583 *****5063 01/06 04:54
1/13 POS PURCHASE Non-PIN 40.58 6,564.95
PNS* SOUTHWEST RECOVERY 214-3878068 TX
INB700 *****5063 01/10 04:04
1/14 OUTGOING WIRE FEE 10.00 6,554.95
1/14 WIRE/OUT BNF:PUNELLI PARTNERS LIMITED CO 2,000.00 4,554.95
1/15 OUTGOING WIRE FEE 10.00 4,544.95
1/15 WIRE/OUT BNF: JAMES PUNELLI 589.33 3,955.62
1/16 POS PURCHASE Non-PIN 14.95 3,940.67

VBS*VONAGE BUSINESS 866-901-0242 GA
INP900 *****5063 01/15 21:31

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PANTHERA TRAINING CENTER LLC Account Number: 4
Date: 01-31-20
Images: 0
Transaction Detail
“Date Activity Description Deposits Withdrawals Balance
POS PURCHASE Non-PIN 01 3,940.66
VBS*VONAGE BUSINESS 866-901-0242 GA
INBBOO *****5063 01/15 21:31
Ref 0280720 from Dep 1080067414 Misappli 22,232.40 26,173.06
ed SOCOM payment
OUTGOING WIRE FEE 10.00 26,163.06
WIRE/OUT BNF:PUNELLI PARTNERS LIMITED CO 4,000.00 22,163.06
OUTGOING WIRE FEE 10.00 22,153.06
WIRE/OUT BNF:PUNELLI PARTNERS LIMITED CO 966.77 21,186.29
OUTGOING WIRE FEE 10.00 21,176.29
WIRE/OUT BNF:PUNELLI PARTNERS LIMITED CO 1,200.00 19,976.29
POS PURCHASE Non-PIN 266.81 19,709.48
EASYJET K1CMMCB EASYJET GB
INP900 *****5063 01/29 21:45
POS PURCHASE FEE 8.00 19,701.48
ITA FEES EASYJET KICMMC EASYJET GB
INPS900 *****5063 01/29 21:45
POS PURCHASE Non-PIN 297.00 19,404.48
HOTEL BOOKING@CANCELON HTTPSWWW.CANC DE
INO700 *****5063 01/29 23:00
POS PURCHASE Non-PIN 276.00 19,128.48
HOTEL BOOKING@CANCEKLON HTTPSWWW.CANC DE
INC900 *****5063 01/29 23:00
POS PURCHASE Non-PIN 2,861.53 16,266.95
ICELANDAIR 10824093503 REYKJAVIK IS
591372 *****5063 01/28 20:15
POS PURCHASE FEE 85.85 16,181.10

1/31

ITA FEES

ICELANDAIR 108240 REYKJAVIK IS

591372 *****5063 01/28 20:15

BATES-PT- 015
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31

Atlantic
Union Bank

PANTHERA TRAINING CENTER LLC

Entered 06/08/20 11:55:42 Page 25 of

215 DEPOT CT SE FL 2 Page 1 of 2
LEESBURG VA 20175-3017 Account Number: 44
Date 02/29/20
Images: 0
Are you doing enough to protect your business? Human error can be the
gateway to a cyberattack. Encourage your employees to not open
suspicious emails, avoid unknown websites, and not download any software
to their work computers. Visit AtlanticUnionBank.com for more tips.
STATEMENT SUMMARY AS OF 02/29/20
Account Name Account Number Interest Paid Balance
In 2019
SMALL BUSINESS CHECKING GD 54: .00 11,559.37
SMALL BUSINESS CHECKING PANTHERA TRAINING CENTER LLC Acct Gap +4
Beginning Balance 2/01/20 16,181.10
Deposits / Misc Credits 3 104,864.80
Withdrawals / Misc Debits 21 109,486.53
** Ending Balance 2/29/20 11,559.37 **
Service Charge .00
Average Balance 15,843
Average Collected Balance 15,843
Minimum Balance 2,514
Transaction Detail
“Date Activity Description Deposits Withdrawals Balance
2/03 OUTGOING WIRE FEE 10.00 16,171.10
2/03 OUTGOING WIRE FEE 10.00 16,161.10
2/03 WIRE/OUT BNF:PUNELLI PARTNERS LIMITED CO 12,500.00 3,661.10
2/03 WIRE/OUT BNF:JAMES PUNELLI 800.00 2,861.10
2/05 ATLANTIC UNION/BEB FEES 30.00 2,831.10
PANTHERA ENTERPR
2/06 POS PURCHASE Non-PIN 206.86 2,624.24
VBS*VONAGE BUSINESS 866-901-0242 GA
IN7200 *****5063 02/05 22:21
2/06 POS PURCHASE Non-PIN 109.60 2,514.64
PALMETTO TECHNOLOGY GR 864-436-7189 SC
058583 *****5063 02/05 03:45
2/12 WIRE/IN ORG: PANTHERA ENTERPRISES LLC 30,200.00 32,714.64
2/12 INCOMING WIRE FEE 15.00 32,699.64
2/12 OUTGOING WIRE FEE 10.00 32,689.64
2/12 WIRE/OUT BNF:PUNELLI PARTNERS LIMITED CO 20,000.00 12,689.64
2/13 DCD/Misc Pay 30,200.00 42,889.64
PANTHERA TRAININ
2/18 OUTGOING WIRE FEE 10.00 42,879.64
2/18 WIRE/OUT BNF:PANTHERA ENTERPRISES LLC 34,160.00 8,719.64
2/21 POS PURCHASE Non-PIN 2,009.53 6,710.11

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A

31

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Page 2 of 2
PANTHERA TRAINING CENTER LLC Account Number: 44
Date: 02-29-20
Images: 0
Transaction Detail
Date Activity Description Deposits Withdrawals Balance
FLIGHTNETWORK-FLIGHTS 855-9769102 WA
000000 *****5063 02/20 03:23
2/21 GO DADDY/WEB ORDER 226.70 6,483.41
Punelli
2/24 DCD/Misc Pay 44,464.80 50,948.21
PANTHERA TRAININ
2/24 OUTGOING WIRE FEE 10.00 50,938.21
2/24 WIRE/OUT BNF:PUNELLI PARTNERS LIMITED CO 8,626.65 42,311.56
2/24 POS PURCHASE Non-PIN 299.99 42,011.57
DNH*GODADDY.COM 480-5058855 AZ
292830 *****5063 02/22 20:01
2/25 POS PURCHASE with PIN 15.50 41,996.07
USPS KIOSK 51510 LEESBURG VA 009550
*****50O63 02/25 09:49
2/26 OUTGOING WIRE FEE 10.00 41,986.07
2/26 WIRE/OUT BNF:PANTHERA ENTERPRISES LLC 30,200.00 11,786.07
2/28 GO DADDY/WEB ORDER 226.70 11,559.37

Punelli

BATES-PT- 017
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31
4 Union Bank

PANTHERA TRAINING CENTER LLC

215 DEPOT CT SE FL 2 Page 1 of 1

LEESBURG VA 20175-3017 Account Number: 44
Date 03/31/20
Images: 0

The current COVID-19 situation we are facing is unprecedented. In these
times of uncertainty, our commitment to clients, Teammates and
communities remains strong. As always, your Relationship Manager is
available to answer questions and provide assistance.

STATEMENT SUMMARY AS OF 03/31/20

Account Name Account Number Interest Paid Balance
In 2019
SMALL BUSINESS CHECKING Ga +4 00 709.37
SMALL BUSINESS CHECKING PANTHERA TRAINING CENTER LLC Acct Gas 44
Beginning Balance 3/01/20 11,559.37
Deposits / Misc Credits 0 .00
Withdrawals / Misc Debits 5 10,850.00
** Ending Balance 3/31/20 709.37 **
Service Charge .00
Average Balance 1,061
Average Collected Balance 1,061
Minimum Balance 709

Transaction Detail

Date Activity Description Deposits Withdrawals Balance
3/02 OUTGOING WIRE FEE 10.00 11,549.37
3/02 OUTGOING WIRE FEE 10.00 11,539.37
3/02 WIRE/OUT BNF:PUNELLI PARTNERS LIMITED CO 10,000.00 1,539.37
3/02 WIRE/OUT BNF:JAMES PUNELLI 800.00 739.37
3/04 ATLANTIC UNION/BEB FEES 30.00 709.37

PANTHERA ENTERPR
31

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Union Bank

A

PANTHERA TRAINING CENTER LLC

No. 2:19-bk-00787 Doc162_ Filed 06/08/20

Entered 06/08/20 11:55:42 Page 28 of

215 DEPOT CT SE FL 2 Page 1 of 1
LEESBURG VA 20175-3017 Account Number: 44
Date 04/30/20
Images: 0
Anytime. Anywhere. Do your business banking remotely with Mobile
Banking. Check balances, pay bills, make deposits - however you bank,
we've got you covered. Download Atlantic Union Bank's mobile app at the
App Store or Google Play today.
STATEMENT SUMMARY AS OF _—— 04/30/20
Account Name Account Number Interest Paid Balance
In 2019
SMALL BUSINESS CHECKING GRE +: .00 3,684.37
SMALL BUSINESS CHECKING PANTHERA TRAINING CENTER LLC Acct 8521808544
Beginning Balance 4/01/20 709.37
Deposits / Misc Credits 1 3,020.00
Withdrawals / Misc Debits 2 45.00
** Ending Balance 4/30/20 3,684.37 **
Service Charge .-00
Average Balance 981
Average Collected Balance 981
Minimum Balance 679

Transaction Detail

Date Activity Description Deposits Withdrawals Balance

4/03 ATLANTIC UNION/BEB FEES 30.00 679.37
PANTHERA ENTERPR

4/28 WIRE/IN ORG: PANTHERA TRAINING, LLC 3,020.00 3,699.37

4/28 INCOMING WIRE FEE 15.00 3,684.37

BATES-PT- 019
No. 2:19-bk-00787 Doc162 Filed o6108i20 Entered 06/08/20 11:55:42 Page 29 of

_ Atlantic
4 Union Bank

June 5, 2020

DOUGLAS E KAHLE
308 CEDAR LAKES DRIVE, 2“° FLOOR

CHESAPEAKE, VA 23322

In Re: PANTHERA TRAINING
Dear Douglas Kahle, Esquire

In response to the follow-up request for account information dated June 04, 2020 phone call. The
transaction of $8,100.00 was not actual wire but an online transaction between Panthera Training
Center LLC and Panthera Worldwide LLC. The date of this transaction was October 21,2019 11:09 am.

If you have any questions or concerns relative toc our response, please contact me at the numbers listed
below.

Sincerely,

William Vaughan

Centralized Fulfillment Representative

Atlantic Union Bank

PO Box 940

Ruther Glen, VA 22546

P 804-448-0751 T 804-589-3065 F 804-633-1415
william.vaughan@atlanticunionbank.com

BATES-PT- 020


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