Declaration
- Date
- 2021-05-21
Summary
A declaration under 28 U.S.C § 1746, filed May 21, 2021 as Doc 346-6 and labelled Exhibit E, in the Chapter 7 case of Panthera Enterprises, LLC, BK No. 2:19-bk-00787, in the U.S. Bankruptcy Court for the Northern District of West Virginia, on a matter brought by movant West Virginia Economic Development Authority. The declarant, the manager and CEO of the company that took over operation of a security operations training facility on the debtor's real property in Hardy County on June 1, 2018, describes 6 buildings built from 38 modular building units. The declaration states the buildings were purchased by the debtor on or about July 23, 2015, rest on cinder blocks set on concrete foundations with metal straps, and are connected to sewer, electrical and water service. It identifies photographs and a contract-of-sale exhibit depicting each building and its use.
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No. 2:19-bk-00787 Doc 346-6 Filed 05/21/21 Entered 05/21/21 10:00:23 Page 1
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EXfflBIT E
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IN THE UNITED STATES BANKRUPTCY COURT
FOR THE NORTHERN DISTRICT OF WEST VIRGINIA
Inre:
BKNo.2:19-bk-00787
PANTHERA ENTERPRISES,LLC,
Chapter 7
Debtor
WEST VIRGINIA ECONOMIC
DEVELOPMENT AUTHORITY,
Movant
V.
PANTHERA ENTERPRISES,LLC,
Respondent
DECLARATION
Pursuant to 28 U.S.C § 1746,the undersigned Robert L. Starer states as follows:
1. I am the Manager and CEO of Pantfaera Training, LLC("Trmmng"). I make this
Déclaration based iqîon my personal knowledge ofthe facts stated herein.
2. On June 1, 2018, Training took over opération of the secuiity opérations training
facility("Facilitv")conducted at the Debtor's real property located in Hardy County,West Virginia
("Real Propertv"L Since June 1,2018,Training has conducted training at the Facility and leased
and maintained the Real Property together with the improvements,structures and buildings located
thereon.
3. There are 6 buildings on the Real Property that have been refened to as the
"Modular Buildings." These 6 buildings were constructed using 38 modulai building units or
components. These Modular Buildings were purchased by the Debtor on or about July 23,2015.
To my knowledge, the Modular Buildings have been on the Real Property since before July 23,
2015,and they have always been used in and for the opération ofthe Facility on the Real Property.
4. The Modular Buildings are attached to the Real Property. The Modular Buildings'
undercarriages sit on cinder blocks, vdiich are set on concrète foundations, with the undercairiage
afïîxed to the ground with métal stiaps. The métal straps are, in tum, attached to large augers
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drilled into the ground. The Modular Buildings are permanendy connected to sewer and electrical
services and a fresh water supply.
5. The above-described means ofannexing the Modular Buildings to the real property
were already in place when Training took over opération ofthe Facility.
6. Attached as Exhibit B to this Déclaration is the Exhibit B that was attached to the
Contract of Sale, pursuant to which the Debtor purchased the modular units. There are sbc
buildings depicted in the Contract ofSale Exhibit B, which are:
• on page 7 of Exhibit B,the "track classrooms" building located in the area of
the paved track, which are constructed with 10 ofthe modular units;
• on page 8 of Exhibit B, beginning from the left, fîrst the kitchen and eating
facility constructed with 5 modular units; second, the main or "upper'*
classroom building, constructed with 12 modular units; third. the office
headquarters, constructed with 4 modular units; and fourth. a building
containing offices available to clients, also constructed with 4 modular units;
• on page 9 of Exhibit B,the "range classrooms" building which located in the
area ofthe shooting ranges,constructed with 3 modular units.
The six buildings shown in Exhibit B to the Contract ofSale are in the same configuration and use
today.
7. The photographs attached as Exhibits Al through A4 depict the'^range classroom
building** and one ofits typical classrooms. These classrooms are used in connection with weapons
courses conducted on the Facility*s shooting ranges. Exhibit A3 depicts the permanent electric
service connection that is typical with each ofthe Modular Buildings. Exhibit A4 is a picture of
undemeath this building showing how it is mounted on cinder blocks which in tum are attached to
concrète foundations.
8. The Facility*s **track classroom building** is shown in the photographs attached as
Exhibits Cl and 02. As the name suggests, each of the driving courses conducted on the
Facility*s three tracks involve some amount ofclassroom training conducted in this building. The
photograph attached as Exhibit02is ofone ofthe large classrooms in this building. Four modular
units were needed to construct this classroom.
9. The photographs attached as Exhibits D1 through D3 show the upper classroom
building. Exhibit D3 is a photograph ofone ofthe tjrpical classrooms contained in this building.
Exhibit D2 is the padded close quarters combat room located in this building. Virtually ail ofthe
training courses conducted at the Facility involve the use ofone or more ofthe classrooms located
in this building.
10. Exhibits El through E3 are photographs of the dining hall, its dining room and
kitchen. Five modular units were required to construct the dining room shown in E2.
11. Exhibits FI through F3 show the Facility*s headquarters building where the
réception and check-in area, conférence room and administrative offices are located.
12. Lastly, Exhibits G1 through G2 show the building that contains offices used by
the Facility*s clients and a typical client office.
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13. Each of these Modular Buildings been constructed, adapted or modified in their
unique way to serve the Facility's needs and purpose as a security opérations tactical training
facility.
1 déclaré under penalties ofpeijuiy that the foregoing is true and correct Executed this 19^
day ofMay,2021.
Robert L. Starer
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