EXHIBIT

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Case 9:20-cv-81205-RAR Document 84-2 Entered on FLSD Docket 08/04/2020 Page 1 of 3
1 Global Capital, LLC and 1 West Capital, LLC

Liquidation Analysis

Plan

of Liquidation Chapter 7

Cash Balance 1 $88,819,000 $88,819,000

Future Collections Estimates

MCA 2 $15,000,000 $7,500,000

Litigation - Collections 3 $5,500,000 $4,125,000

Receivership 4 $4,500,000 $4,500,000

Litigation - Bankruptcy 5 $4,000,000 $2,000,000

$29,000,000 $18,125,000

Gross Recovery Estimate 6 $117,819,000 $106,944,000

Administration Claims:

Fees/holdback through 10-01-19 7 ($2,000,000) ($2,000,000)

Operating Budget thru 10-01-19 8 ($1,077,000) ($1,000,000)

Insurance 9 ($150,000)

Prof Fees Thru Confirmation 10-01-19 10 ($3,339,000) ($3,339,000)

Total Administration Claims ($6,566,000) ($6,339,000)

Projected Total Cash for Trust $111,253,000 $100,605,000

Liquidating Trust Expenses - Operating Period

Operating Budget 11 ($681,000) ($500,000)

Professional Fees 12 ($1,758,000) ($5,000,000)

US Trustee Fees 13 ($600,000)

Chapter 7 Fee (3%) 14 ($3,018,150)

Non Operating Professional Fees 15 ($2,000,000)

Total Plan Expenses ($5,039,000) ($8,518,150)

Projected Cash to Distribute $106,214,000 $92,086,850

Secured and Priority Claims

Secured claims 16 ($2,500,000) ($2,500,000)

Priority claims 17 ($1,000,000) ($1,000,000)

Sub Total ($3,500,000) ($3,500,000)

Projected Cash to General Unsecured Claims 18 $102,714,000 $88,586,850

Estimate of Claims Basis 19 $300,000,000 $400,000,000

Projected Distribution Recovery 20 34% 22% NOTES

August 1, 2019

Case 9:20-cv-81205-RAR Document 84-2 Entered on FLSD Docket 08/04/2020 Page 2 of 3 Case 18-19121-RBR Doc 806-4 Filed 07/22/19 Page 2 of 3
1 Global Capital, LLC and 1 West Capital, LLC

Liquidation Analysis

NOTES:

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August 1, 2019

Cash balance is as of July 15, 2019.

MCA portfolio collections managed in house by the collection department with a team in 

place. 

Litigation collections are outside contingent collection firms.

Chapter 7 compensation is capped at a statutory 3% fee.

Non Operating Professional fees includes fees for counsel, accountants and litigation matters 

for the duration of the case post operations.

Receivership matters include future receipts from Bright Smile, Ganador and other 

receivership related matters.

Litigation - Bankruptcy is an estimate of general bankruptcy litigation matters, including

preference and avoidance matters and professional litigation.

Gross recovery estimate is a projection and may materially change.

Projection of professional fee holdbacks for the Chapter 11 period.

Operating Budget is staff and operations through the plan Effective Date.

Insurance includes Director and Officer insurance.

Secured claims are currently an estimate, subject to further review and objections.

Priority claims are currently an estimate, subject to further review and objections.

Projected Cash to distribute is an estimate, subject to material changes and will occur over a 

time period of one to three years.

Projected distribution and recovery is a projection based upon a number of estimates for the 

amount of recoveries and the amount of costs incurred and to be incurred by the estate to 

finalize the matter.

The current estimate does not include: 

* The SEC claim of $285,599,532, which the Plan Proponents believe will resolved 

consensually. 

* The Travis, Oliphant and Collins claims totaling $151,778,601, subject to pending 

objection and pending litigation. 

The estimate of claims basis is a projection assuming gross claims will be reduced to an 

amount in this range. Material changes can occur to the final claims basis. The claims basis 

will likely be higher in a Chapter 7. 

Professional Fees includes an estimate of fees yet to be incurred through October 1.

Liquidating Trust expenses are a budget and at a run rate through December 31, 2019.

Professional fees are related to the Liquidating Trust. Chapter 7 Fees would be materially 

higher based upon a new team and a new strategy to manage the matter.

US Trustee Fees are estimated based upon distributions.

Case 9:20-cv-81205-RAR Document 84-2 Entered on FLSD Docket 08/04/2020 Page 3 of 3 Case 18-19121-RBR Doc 806-4 Filed 07/22/19 Page 3 of 3