Kristen E. Burgers (VSB No. 67997)

HIRSCHLER FLEISCHER

8270 Greensboro Drive, Suite 700

Tysons, Virginia 22102

Telephone: (703) 584-8900

Facsimile: (703) 584-8901

Email: kburgers@hf-law.com

Co-Counsel to the Debtors

Mark S. Lichtenstein (Admitted pro hac vice)

Crowell & Moring LLP

590 Madison Avenue, 20th Floor

New York, New York 10022

Telephone: (212) 223-4000

Facsimile: (212) 223-4001

Email: mlichtenstein@crowell.com

Co-Counsel to the Debtors

IN THE UNITED STATES BANKRUPTCY COURT 

FOR THE EASTERN DISTRICT OF VIRGINIA

Alexandria Division

)

In re: )

) Chapter 11

GreenTech Automotive, Inc., et al.1) Case No. 18-10651

) Jointly Administered

Debtor. )

)

CERTIFICATION OF BALLOT REPORT FOR 

THE FOURTH AMENDED JOINT CHAPTER 11 PLAN OF LIQUIDATION OF

GREENTECH AUTOMOTIVE, INC. AND WM INDUSTRIES CORP.

I, Mark Lichtenstein, a partner of Crowell & Moring LLP, hereby certify under penalty of 

perjury, that the Ballot Report annexed hereto (the “Ballot Report”) as Exhibit A accurately 

reflects the voting of creditors for all ballots received by August 16, 2019. The chart below 

summarizes the Ballot Report.

ACCEPTING2 REJECTING

CLASS # % AMOUNT % # % AMOUNT %

1 1 100% $465,133.05 100% 0 0% $0.00 0%

2 1 100% $394,000.00 100% 0 0% $0.00 0%

3 1 100% $50,000,000.00 100% 0 0% $0.00 0%

6 3 100% $29,700,653.02 100% 0 0% $0.00 0%

 

1

 The Debtors in these jointly administered chapter 11 cases are GreenTech Automotive, Inc. (Case No. 18-10651), 

WM Industries Corp. (Case No. 18-10652), Gulf Coast Funds Management, LLC (Case No. 18-10653), American 

Immigration Center, LLC (Case No. 18-10654), GreenTech Automotive Capital A-3 GP, LLC (Case No. 18-10655), 

and GreenTech Automotive Partnership A-3, L.P. (Case No. 18-10656).

2 Classes 4 and 5 are unimpaired and thus deemed to accept. Classes 7, 8, 9, 10, and 11 are impaired and thus 

deemed to reject. 

Case 18-10651-BFK Doc 618 Filed 08/21/19 Entered 08/21/19 17:16:42 Desc Main

 Document Page 1 of 10
- 2 -

I further certify that the Investor Consent Report annexed hereto (the “ Investor Consent 

Report”) accurately reflects the voting of A-3 and A-4 Investors for all Investor Consents (as 

defined in the Debtors’ Fourth Amended Joint Chapter 11 Plan of Liquidation (the “Plan”)) 

received by August 16, 2019. The chart below summarizes the Investor Consent Report.

INVESTOR # OF INVESTORS ELECTING TO OPT-IN # OF INVESTORS DECLINING TO OPT-IN

A-3 51 0

A-4 69 0

Dated: August 21, 2019 Respectfully submitted,

/s/ Mark S. Lichtenstein

Mark S. Lichtenstein (admitted pro hac vice)

CROWELL & MORING LLP

590 Madison Ave., 20th Fl.

New York, NY 10022

Telephone: (212) 895-4267

Facsimile: (212) 223-4134

Email: mlichtenstein@crowell.com

Counsel to the Debtors

/s/ Kristen E. Burgers

Kristen E. Burgers (VSB No. 67997)

HIRSCHLER FLEISCHER

8270 Greensboro Drive, Suite 700

Tysons, Virginia 22102

Telephone: (703) 584-8900

Email: kburgers@hf-law.com

Local Counsel to the Debtors

Case 18-10651-BFK Doc 618 Filed 08/21/19 Entered 08/21/19 17:16:42 Desc Main

 Document Page 2 of 10
Ballot Report

CLASS 1

Investor Voting Amount

Tunica County, Mississippi FOR: $465,133.05

Total: $465,133.05 

CLASS 2

Investor Voting Amount

Tunica County, Mississippi FOR: $394,00.00

Total: $394,000.00 

CLASS 3

Investor Voting Amount

GreenTech Automotive Partnership A-3, L.P. FOR: $50,000,0001

Total: $50,000,000

CLASS 4

Unimpaired, Deemed to Accept

CLASS 5

Unimpaired, Deemed to Accept

CLASS 6

Investor Voting Amount

State of Mississippi, Mississippi Development 

Authority FOR: $3,494,653.02

Tunica County, Mississippi FOR: $1,606,000.00

Virtual Integrated Analytics Solutions Inc. Ballot not received

Quality Metalcraft, Inc. Ballot not received

Swoosh Technologies & Solutions Ballot not received

Futuris Auto Interiors Ballot not received

Akerman LLP IOLA Account Ballot not received

Sheehan & Associates, PLC Ballot not received

Honigman Miller Schwartz & Cohen Ballot not received

P7/Buchanan Pinkard Lakeside Ballot not received

Oakley Industries Ballot not received

GreenTech Automotive Partnership A-3, L.P.2 FOR: $24,600,000.00

P7 Buchanan Pinkard Lakeside Ballot not received

 

1 The actual A-3 LP Secured Claim is in the amount of $4,706,870.59. 

2 All 53 A-3 Investors who submitted a completed Class 6 Ballot accepted the Plan (there are 89 A-3 Investors in 

total).

Case 18-10651-BFK Doc 618 Filed 08/21/19 Entered 08/21/19 17:16:42 Desc Main

 Document Page 3 of 10
Total: $29,700,653.023

CLASS 7

Impaired, Deemed to Reject

CLASS 8 

Impaired, Deemed to Reject

CLASS 9

Impaired, Deemed to Accept

CLASS 10

Impaired, Deemed to Reject

CLASS 11

Impaired, Deemed to Reject

 

3 The total claims in the Class are in the amount of $30,354,990.31. Thus, 100% of Creditors that voted, voted in 

favor, and nearly 100% of the aggregate claims in the Class voted in favor.

Case 18-10651-BFK Doc 618 Filed 08/21/19 Entered 08/21/19 17:16:42 Desc Main

 Document Page 4 of 10
Investor Consent Report 

A-3 Investors

Investor Election

Tang Bixiang Consent not received

Shao Yunxia Opt-in

Wang Yue Consent not received

Zhang Nianqing Opt-in

Wang Zhiwei Opt-in

Jiang Limei Consent not received

Wang Rui Consent not received

Li Jing Opt-in

Yao Junping Consent not received

Tang Xiaonan Opt-in

Zhao Huibin Opt-in

Chen Yuanyuan Opt-in

Lu Huibin Opt-in

Liu Jiahong Opt-in

Ling Hao Opt-in

Huang Jun Opt-in

Li Zhonghui Consent not received

Li Chunsheng Consent not received

Yu Houqian Consent not received1

Han Bing Opt-in

Geng Tianyang Opt-in

Liao Fangfang Opt-in

Xiong Shie Consent not received

Wang Chun Consent not received

Qin Zheng Consent not received2

Zhang Weihua Opt-in

Fang Jiande Opt-in

Liu Xiaoyan Opt-in

Li Li Opt-in

Wu Jian Consent not received 

Zhang Xuemei Consent not received

Cheng Qingli Opt-in

Lin Lin Consent not received

Hu Dongsheng Opt-in

 

1 Received Investor Consent, but investor neither elected nor declined to opt-in.

2 Received Investor Consent, but investor neither elected nor declined to opt-in.

Case 18-10651-BFK Doc 618 Filed 08/21/19 Entered 08/21/19 17:16:42 Desc Main

 Document Page 5 of 10
Cui Jie Opt-in

He Li Opt-in

He Baihui Opt-in

Shen Meiming Consent not received

You Jin Opt-in

Zhao Yan Consent not received

Bi Xia Consent not received 

Liu Xianhai Consent not received

Wang Yahong Consent not received

Tan Yunping Consent not received

Zhang Zhenjun Opt-in

Gao Chun Opt-in

Cheng Ying Consent not received

Zhang Wang Opt-in

Zhen Yu Opt-in

Ling Lui Opt-in

Wang Rui Consent not received 

Luo Yingshu Opt-in

Yan Lina Consent not received

Liu Lan Consent not received

Zhang Guosheng Opt-in

Chen Nian Consent not received

Zeng Wei Consent not received

Le Kui Consent not received

Fan Yali Consent not received

Li Xinmin Opt-in

Cai Zhiqiang Opt-in

Zhang Shengbo Opt-in

Zhong Fumin Opt-in

Dai Yuqing Opt-in

Gu Jun Consent not received

Yang Xiaohong Consent not received

Wang Ning Opt-in

Liang Hui Opt-in

Xu Jing Opt-in

Dong Yue Opt-in

Wan Ling Opt-in

Liu Jian Consent not received

Zhang Yunhai Opt-in

Cui Tao Consent not received

Li Ying Opt-in

Case 18-10651-BFK Doc 618 Filed 08/21/19 Entered 08/21/19 17:16:42 Desc Main

 Document Page 6 of 10
Long Gan Opt-in

Tao Lei Opt-in

Yang Dong Consent not received

Liu Jinhua Opt-in

Yang Xin Opt-in

Chen Meirong (now Chen Ran) Opt-in

Chen Ying Consent not received

Lu Xiaoshuang Opt-in

An Tingting Consent not received

Teng Lei Consent not received

Lei Yan Opt-in

Zhang Yifei Opt-in

Zhan Xu Consent not received

Han Zhuoni Consent not received

A-4 Investors

Investor Election

Wang Fang Opt-in

Qi Xuemei Consent not received

Li Heng Consent not received

Ma Chaosong Opt-in

Wang Jing Consent not received

Zhang Jinying Opt-in

Sun Jiang Consent not received

Zhang Le Opt-in

Chowdappa Jayaramaiah Consent not received

Zhang Ziyin Opt-in

Du Xiaojuan Consent not received

Wei Ming Opt-in

Jiang Jiabo Opt-in

Bian Xinmin Consent not received

Zhao Xuejun Opt-in

Li Xiaolu Consent not received

Li Jun Opt-in

Cui Weiying Opt-in

Jin Ning Opt-in

Huang Ying Consent not received

Li Na Consent not received

Zhang Yang Opt-in

Fang Weiming Opt-in

Case 18-10651-BFK Doc 618 Filed 08/21/19 Entered 08/21/19 17:16:42 Desc Main

 Document Page 7 of 10
He Yimin Opt-in

Ma Yun Opt-in

Chen Wen Opt-in

Wang Xin Opt-in

Wang Zijun Opt-in

Kong Gezi Opt-in

Jiang Xiaoxiao Opt-in

Li Lixia Opt-in

Tian Yue Opt-in

Chai Xudong Opt-in

Li Jun Consent not received

Li Yan Opt-in

Jiang Liya Opt-in

Ma Jing Opt-in

Yang Yiwen Consent not received

Sheng Lijun Opt-in

Zou Liangguang Opt-in

Sun Pin Opt-in

Sun Tingye Opt-in

Chen Juan Opt-in

Liang Tao Opt-in

Xu Hui Opt-in

Wang Zongang Opt-in

Dong Gang Opt-in

Ying Hongbo Opt-in

Wu Xiaoyan Opt-in

Peng Linyan Opt-in

Yang Wen Consent not received

Guo Chunlei Opt-in

Hu Gongde Opt-in

Lu Chengwei Opt-in

Li Donghong Opt-in

Lin Ying Opt-in

Li Qinyu Consent not received

Ma Lin Opt-in

Shou Yuying Consent not received

Jiang Huifen Opt-in

Yang Man Opt-in

Yu Zhitao Opt-in

Lin Jie Consent not received

Ai Yinqian Opt-in

Case 18-10651-BFK Doc 618 Filed 08/21/19 Entered 08/21/19 17:16:42 Desc Main

 Document Page 8 of 10
Mu Xin Opt-in

Li Jing Opt-in

Shi Jin Opt-in

Zhang Jianyu Opt-in

Wang Wenjie Opt-in

Gong Zhongqiu Consent not received

Feng Qiuhong Opt-in

Zhang Ying Opt-in

Ma Like Consent not received

Shen Jing Opt-in

He Xiaohua Opt-in

Zhang Hao Opt-in

Chong Mei Opt-in

Gao Tianqun Opt-in

Shi Lizheng Opt-in

Xu Shitong Opt-in

Hao Lijun Opt-in

Zhang DeHong Opt-in

Zhao Xiaoning Consent not received

Wang Xianzhe Opt-in

Wang Yandong Opt-in

Su Yingying Opt-in

Cao Lixin Consent not received

Liu Xiaowei Consent not received

Zhou Cheng Consent not received

Cao Guohua Consent not received

Ji Fang Consent not received

Yang Wen Opt-in

Sun Jinjin Consent not received

Wu Hongli Consent not received

Yin Fang Consent not received

Yang Hongbin Consent not received

Hou Xiaoping Consent not received

Song Siyu Consent not received

Hu Cailan Consent not received

Wang Huanyu Consent not received

Xin Jilefu Consent not received

Liu Siyu Consent not received

Zhao Xiaoning Opt-in

Case 18-10651-BFK Doc 618 Filed 08/21/19 Entered 08/21/19 17:16:42 Desc Main

 Document Page 9 of 10
CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on this 21st day of August, 2019, a copy of the foregoing 

Certification of Ballot Report for the Fourth Amended Joint Chapter 11 Plan of Liquidation of 

GreenTech Automotive, Inc. and WM Industries Corp.was served via this Court’s CM/ECF 

electronic filing service on all parties entitled to receive notice thereby.

/s/ Kristen E. Burgers

Kristen E. Burgers

11495692.1 043227.00001

Case 18-10651-BFK Doc 618 Filed 08/21/19 Entered 08/21/19 17:16:42 Desc Main

 Document Page 10 of 10