UNITED STATES BANKRUPTCY COURT 

SOUTHERN DISTRICT OF FLORIDA 

FT. LAUDERDALE DIVISION 

www.flsb.uscourts.gov 

In Re: 

 Chapter 11 

WHOA NETWORKS, INC., a Florida Corp., Case No.: 20-21883-BKC-SMG 

WHOA NETWORKS, INC., a Delaware Corp. Case No.: 20-21884-BKC-SMG 

HIPSKIND TECHNOLOGY SOLUTIONS Case No.: 20-21885-BKC-SMG 

 GROUP INCORPORATED, 

PLATINUM SYSTEMS HOLDINGS, LLC, Case No.: 20-21886-BKC-SMG 

Debtors. (Jointly Administered under 

________________________________/ Case No.: 20-21883-BKC-SMG)

STIPULATION AND JOINT MOTION FOR ENTRY OF AGREED 

ORDER GRANTING ADEQUATE PROTECTION AND RELATED 

RELIEF TO HEWLETT-PACKARD FINANCIAL SERVICES COMPANY 

WHOA NETWORKS, INC., (the “Whoa Florida Debtor”) and HIPSKIND 

TECHNOLOGY SOLUTIONS GROUP INCORPORATED, (the “Hipskind Debtor”) two of 

the four above-captioned debtors (collectively, the “Debtors”) and secured creditor, HewlettPackard Financial Services Company (“Creditor” or “HPFSC”) by and through their respective 

counsel, hereby stipulate, agree and jointly move the Court for entry of an Agreed Order in the 

form attached hereto as Exhibit “A” approving the agreement between the Whoa Florida Debtor, 

Hipskind Debtor and HPFSC (collectively, the “Parties”) (A) providing for adequate protection of 

the secured claim of HPFSC by the Hipskind Debtor, and (B) other related relief (the “Motion”). 

In support of the Motion, the Parties state as follows: 

I. JURISDICTION 

1. The Court has jurisdiction over this stipulation and joint Motion pursuant to 28 U.S.C. 

§§ 157 and 1334. 

2. The Motion is a core proceeding pursuant to 28 U.S.C. § 157(b)(2). 

Case 20-21883-SMG Doc 163 Filed 03/23/21 Page 1 of 26
2 

3. Venue of the Motion, and the Case, is proper before this Court pursuant to 28 

U.S.C. §§ 1408 and 1409. 

II. BACKGROUND 

4. On October 29, 2020 (the “Petition Date”), each of the Debtors filed a voluntary 

petition in this Court for relief under Chapter 11 of Title 11 of the United States Code (the 

“Bankruptcy Code”). Since that time, the Debtors have operated as debtors-in-possession pursuant 

to Sections 1107 and 1108 of the Bankruptcy Code. 

5. As of the date hereof, no creditors’ committee has been appointed in these cases. 

In addition, no trustee or examiner has been appointed. 

6. For a detailed description of the Debtors, their operations and assets and liabilities, 

the Debtors respectfully refer the Court and parties-in-interest to the Declaration of Mark Amarant 

in Support of Chapter 11 Petitions and First Day Motions filed with the Court contemporaneously 

herewith (the “First Day Declaration”)[ECF No.10]. 

III. EQUIPMENT FINANCING AGREEMENTS 

A. Whoa Florida Debtor 

7. Prior to the Petition Date, Whoa Florida Debtor was a party to the following 

equipment financing agreements: 

(i) that certain Business Lease Agreement dated January 30, 2017 (Lease Agreement 

No. 522721772767082USA3), and Amendments thereto (the “USA3 Agreement”); 

(ii) that certain Business Lease Agreement dated June 21, 2017 (Lease Agreement No. 

522721772767105USA4) and Amendments thereto (the “USA4 Agreement”); and 

(iii) that certain Business Lease Agreement dated September 20, 2017 (Lease 

Agreement No. 522721772792646USA5) and Amendments thereto (the “USA5 Agreement”), 

Case 20-21883-SMG Doc 163 Filed 03/23/21 Page 2 of 26
3 

(USA3 Agreement, USA4 Agreement and USA5 Agreements shall be collectively referred to as 

the “Lease Agreements”). A copy of the USA Financing Agreements, their respective 

Amendments, Schedule A and UCC are attached to the Motion. 

8. On December 8, 2020, HPFSC filed a Proof of Claim (Claim #14) asserting an 

unsecured claim in the amount of $178,078.31 (the “Unsecured Claim”). 

 B. Hipskind Debtor 

9. Prior to the Petition Date, the Hipskind Debtor was a party to the following secured 

financing agreements: 

(i) Note and Security Agreement dated March 29, 2018 (Agreement No. 

5398294827000001) (the “Hipskind March 2018 Note”) in the principal amount of $195,400.00; 

and 

(ii) Note and Security Agreement dated July 13, 2018 (Agreement No. 

5398294827000002) (the “Hipskind July 2018 Note”) in the principal amount of $161,342.72 

(collectively, the “Note Agreements”). 

10. On December 16, 2020, HPFSC filed a Proof of Claim (Claim #7) asserting a 

secured claim in the amount of $273,799.29 (the “Hipskind Secured Claim”). 

IV. STIPULATION 

 A. Whoa Florida Debtor 

11. As of the Petition Date, HPFSC represents and warrants that the amount due and 

owing under the Lease Agreements was $178,078.31 (the “ Whoa Florida Claim Amount”). 

12. The Parties have agreed that the Lease Agreements relate solely to professional 

services and not equipment financing. As a result, the Whoa Florida Debtor and HPFSC have 

agreed that HPFSC shall have an allowed general unsecured claim for all purposes in these chapter 

Case 20-21883-SMG Doc 163 Filed 03/23/21 Page 3 of 26
4 

11 cases against the Whoa Florida Debtor in the amount of $178,078.31 (“HPFSC Whoa Florida 

Unsecured Claim”). 

B. Hipskind Debtor 

13. As of the Petition Date, HPFSC represents and warrants that the amount due and 

owing under the Note Agreements was $273,799.29 (the “Hipskind Claim Amount”). 

14. The Parties have agreed that the Note Agreements are secured financing agreements 

whereby HPFSC asserts a security interest and/or lien upon the equipment and/or other personal 

property more specifically described in Exhibit “B” attached hereto (collectively, the “HPFSC 

Equipment” or the “Collateral”)1 and has a fair market value of $75,000.00. As a result, the 

Hipskind Debtor and HPFSC have agreed that HPFSC shall have an allowed secured claim for all 

purposes in these chapter 11 cases against the Hipskind Debtor in the amount of $75,000.00 

(“HPFSC Secured Claim”) in respect of the HPFSC Equipment and a general unsecured claim in 

the amount of $198,799.29 (“HPFSC Hipskind Unsecured Claim”). 

15. In connection with the foregoing, the Parties have agreed that the Hipskind Debtor 

shall make adequate protection payments to HPFSC during the pendency of this Chapter 11 case 

in respect of the HPFSC Equipment in the amount of $1,415.34 per month (the “Adequate 

Protection Payment”) commencing March 29, 2021 and continuing on the same day of each month 

thereafter through either the effective date of a plan of reorganization in these Chapter 11 cases or 

the date of conversion or dismissal of these Chapter 11 cases. 

16. The Adequate Protection Payment was determined by fully amortizing the 

aggregate allowed HPFSC Secured Claim in the amount of $75,000.00 through equal monthly 

 

1 Claim #7 filed by HPFSC did not include a copy of Exhibit 1 (Financed Items) to Exhibit A to the Note Agreements. 

Accordingly, the Exhibit describing the HPFSC Equipment is attached hereto as Exhibit “B”. 

Case 20-21883-SMG Doc 163 Filed 03/23/21 Page 4 of 26
5 

payments of principal and interest over 60 months (the “Term”) at an annual interest rate of 5.0%. 

17. The Parties further agreed that in connection with any plan of reorganization filed 

by the Hipskind Debtor or Debtors in these Chapter 11 cases, the Debtors agree to separately 

classify the HPFSC Secured Claim from all other classes of claims in such plan and provide for 

the treatment of such allowed HPFSC Secured Claim as set forth hereinabove, namely to continue 

making monthly Adequate Protection Payments to HPFSC for the Term, which payments, if and 

when paid, will satisfy the allowed HPFSC Secured Claim in full. Subject to such treatment being 

provided in any such plan, HPFSC has agreed to vote any and all of its allowed HPFSC Secured 

Claim and HPFSC Hipskind Unsecured Claim to accept and otherwise support such plan. 

18. The Adequate Protection Payment agreed to by the Parties shall be made by wire 

transfer pursuant to instructions to be provided by HPFSC. Any notices to HPFSC shall be sent to 

Hewlett-Packard Financial Services Company, 200 Connell Drive, Suite 5000, Berkeley Heights, 

NJ 07922. Attn: Diane Morgan, Corporate Counsel, email: diane.morgan@hpe.com. 

19. Any applicable sales tax and personal property tax associated with the HPFSC 

Equipment shall be the responsibility of the Hipskind Debtor. 

20. The Hipskind Debtor agrees to maintain insurance coverage on the HPFSC 

Equipment in accordance with the terms of the HPFSC Agreement. 

21. In the event the Hipskind Debtor fails to make the Adequate Protection Payments 

as set forth herein, and such failure continues for a period of three (3) business days after the due 

date thereof, then HPFSC shall email notification of the default to Debtors counsel, Paul J. Battista, 

Esq., at pbattista@gjb-law.com. The Hipskind Debtor shall have a period of two (2) business days 

after such notice to cure such default. If the Hipskind Debtor fails to cure such default, then HPFSC 

may file an affidavit reflecting such default, the notification to cure, and the failure of the Hipskind 

Case 20-21883-SMG Doc 163 Filed 03/23/21 Page 5 of 26
6 

Debtor to cure the default. The Hipskind Debtor shall then have three (3) business days to file a 

counter-affidavit with the Court stating that the Hipskind Debtor is not in default. If the Hipskind 

Debtor fails to file a counter-affidavit by the deadline herein, then the automatic stay imposed by 

11 U.S.C. §362 shall terminate as to the HPFSC Equipment, at which time HPFSC shall be able 

to exercise any and all rights and remedies granted to it under the Note Agreements and under 

applicable state and/or federal law. In connection therewith, HPFSC shall submit an Order to the 

Court lifting the automatic stay imposed by 11 U.S.C. §362 with respect to the HPFSC Equipment, 

which Order the Court may enter without further notice and hearing. 

22. In the event the Hipskind Debtor Chapter 11 case is dismissed or converted to a 

case under Chapter 7, then all Adequate Protection Payments made hereunder shall be applied to 

the debt in accordance with the terms set forth in the Note Agreements, and HPFSC shall be 

entitled to exercise any or all of its rights and remedies against the HPFSC Equipment or the 

Hipskind as permitted pursuant to paragraph 21 above without further notice to the Hipskind 

Debtor or further order of the Court. 

23. Based upon the foregoing, the Parties ask the Court to enter an order approving this 

Stipulation and approving all adequate protection payments made by the Hipskind Debtor to 

HPFSC and other related relief. 

WHEREFORE, the Parties respectfully request that the Court (a) enter the Agreed Order 

attached hereto as Exhibit “A”; and (b) grant such further relief as may be just and proper. 

Dated this 23rd day of March 2021. 

 Respectfully Submitted, 

 GENOVESE JOBLOVE & BATTISTA, P.A. 

 Attorneys for Debtors-in-Possession 

100 Southeast Second Street, Suite 4400 

 Miami, Florida 33131 

Case 20-21883-SMG Doc 163 Filed 03/23/21 Page 6 of 26
7 

 Telephone: (305) 349-2300 

 Facsimile: (305) 349-2310 

 By: /s/ Mariaelena Gayo-Guitian 

 Paul J. Battista, Esq. 

Florida Bar No. 884162 

pbattista@gjb-law.com

Mariaelena Gayo-Guitian, Esq. 

Florida Bar No. 813818 

mguitian@gjb-law.com

 -ANDHEWLETT PACKARD ENTERPRISE 

By: /s/ Kyle Frankeny 

Kyle Frankeny, Corporate Counsel, CSM&A 

Telephone: (888) 342-2156 

E: kyle.frankeny@hpe.com

CERTIFICATE OF SERVICE 

 I HEREBY CERTIFY that a copy of the foregoing was served via CM/ECF Notification 

and or U.S. Mail to all listed below on this 23rd day of March, 2021. 

By: /s/ Mariaelena Gayo-Guitian 

 Mariaelena Gayo-Guitian 

Florida Bar No. 0813818 

mguitian@gjb-law.com

Case 20-21883-SMG Doc 163 Filed 03/23/21 Page 7 of 26
8 

SERVICE LIST 

Served Via CM/ECF Notification 

Vincent F Alexander on behalf of Creditor Fidelity Funding Services, LLC 

vincent.alexander@lewisbrisbois.com, 

claudia.pena@lewisbrisbois.com;ftlemaildesig@lewisbrisbois.com 

Paul J. Battista, Esq on behalf of Debtor Hipskind Technology Solutions Group, Incorporated 

pbattista@gjb-law.com, gjbecf@gjb-law.com;chopkins@gjb-law.com;jzamora@gjblaw.com;gjbecf@ecf.courtdrive.com;vlambdin@gjb-law.com 

Paul J. Battista, Esq on behalf of Debtor Platinum Systems Holdings, LLC 

pbattista@gjb-law.com, gjbecf@gjb-law.com;chopkins@gjb-law.com;jzamora@gjblaw.com;gjbecf@ecf.courtdrive.com;vlambdin@gjb-law.com 

Paul J. Battista, Esq on behalf of Debtor Whoa Networks, Inc., a Delaware Corporation 

pbattista@gjb-law.com, gjbecf@gjb-law.com;chopkins@gjb-law.com;jzamora@gjblaw.com;gjbecf@ecf.courtdrive.com;vlambdin@gjb-law.com 

Paul J. Battista, Esq on behalf of Debtor Whoa Networks, Inc., a Florida Corporation 

pbattista@gjb-law.com, gjbecf@gjb-law.com;chopkins@gjb-law.com;jzamora@gjblaw.com;gjbecf@ecf.courtdrive.com;vlambdin@gjb-law.com 

Paul J. Battista, Esq on behalf of Interested Party Hipskind Technology Solutions Group, 

Incorporated 

pbattista@gjb-law.com, gjbecf@gjb-law.com;chopkins@gjb-law.com;jzamora@gjblaw.com;gjbecf@ecf.courtdrive.com;vlambdin@gjb-law.com 

Paul J. Battista, Esq on behalf of Interested Party Platinum Systems Holdings, LLC 

pbattista@gjb-law.com, gjbecf@gjb-law.com;chopkins@gjb-law.com;jzamora@gjblaw.com;gjbecf@ecf.courtdrive.com;vlambdin@gjb-law.com 

Paul J. Battista, Esq on behalf of Interested Party Whoa Networks, Inc., a Delaware Corporation 

pbattista@gjb-law.com, gjbecf@gjb-law.com;chopkins@gjb-law.com;jzamora@gjblaw.com;gjbecf@ecf.courtdrive.com;vlambdin@gjb-law.com 

Denise D Dell-Powell on behalf of Creditor Western Equipment Finance, Inc. 

ddpowell@deanmead.com, mgodek@deanmead.com 

Mariaelena Gayo-Guitian on behalf of Debtor Hipskind Technology Solutions Group, 

Incorporated 

mguitian@gjb-law.com, gjbecf@gjb-law.com;vlambdin@gjb-law.com;cesser@gjblaw.com;chopkins@gjb-law.com;gjbecf@ecf.courtdrive.com 

Mariaelena Gayo-Guitian on behalf of Debtor Platinum Systems Holdings, LLC 

Case 20-21883-SMG Doc 163 Filed 03/23/21 Page 8 of 26
9 

mguitian@gjb-law.com, gjbecf@gjb-law.com;vlambdin@gjb-law.com;cesser@gjblaw.com;chopkins@gjb-law.com;gjbecf@ecf.courtdrive.com 

Mariaelena Gayo-Guitian on behalf of Debtor Whoa Networks, Inc., a Delaware Corporation 

mguitian@gjb-law.com, gjbecf@gjb-law.com;vlambdin@gjb-law.com;cesser@gjblaw.com;chopkins@gjb-law.com;gjbecf@ecf.courtdrive.com 

Mariaelena Gayo-Guitian on behalf of Debtor Whoa Networks, Inc., a Florida Corporation 

mguitian@gjb-law.com, gjbecf@gjb-law.com;vlambdin@gjb-law.com;cesser@gjblaw.com;chopkins@gjb-law.com;gjbecf@ecf.courtdrive.com 

Heather L Harmon, Esq on behalf of Debtor Whoa Networks, Inc., a Florida Corporation 

HHarmon@gjb-law.com, gjbecf@gjb-law.com;ecastellanos@gjblaw.com;gjbecf@ecf.courtdrive.com;jzamora@gjb-law.com 

Heather L Harmon, Esq on behalf of Interested Party Hipskind Technology Solutions Group, 

Incorporated 

HHarmon@gjb-law.com, gjbecf@gjb-law.com;ecastellanos@gjblaw.com;gjbecf@ecf.courtdrive.com;jzamora@gjb-law.com 

Heather L Harmon, Esq on behalf of Interested Party Platinum Systems Holdings, LLC 

HHarmon@gjb-law.com, gjbecf@gjb-law.com;ecastellanos@gjblaw.com;gjbecf@ecf.courtdrive.com;jzamora@gjb-law.com 

Heather L Harmon, Esq on behalf of Interested Party Whoa Networks, Inc., a Delaware 

Corporation 

HHarmon@gjb-law.com, gjbecf@gjb-law.com;ecastellanos@gjblaw.com;gjbecf@ecf.courtdrive.com;jzamora@gjb-law.com 

Mark Journey on behalf of Creditor Broward County 

mjourney@broward.org, swulfekuhle@broward.org 

Buffey E Klein on behalf of Creditor Johnson Bank 

buffey.klein@huschblackwell.com, legalsupportteam-dreamteamdal@huschblackwell.com;buffey-klein-8494@ecf.pacerpro.com 

Office of the US Trustee 

USTPRegion21.MM.ECF@usdoj.gov 

David A Ray, Esq. on behalf of Creditor Dell Financial Services L.L.C. 

dray@draypa.com, draycmecf@gmail.com;sramirez.dar@gmail.com;drabrams620@gmail.com 

Jason A Rosenthal on behalf of Creditor Bank of the West 

jason@therosenthallaw.com, jmorando@therosenthallaw.com;jennifer@therosenthallaw.com 

Richard B. Storfer, Esq. on behalf of Creditor Balboa Capital Corporation 

Case 20-21883-SMG Doc 163 Filed 03/23/21 Page 9 of 26
10 

rstorfer@rprslaw.com 

Richard B. Storfer, Esq. on behalf of Creditor De Lage Landen Financial Services, Inc. 

rstorfer@rprslaw.com 

Sabrina L Streusand on behalf of Creditor Dell Financial Services L.L.C. 

streusand@slollp.com, villa@slollp.com 

Howard S Toland on behalf of Creditor Radius Bank 

htoland@mitrani.com 

J. Steven Wilkes on behalf of U.S. Trustee Office of the US Trustee 

steven.wilkes@usdoj.gov 

Charles R Woolley on behalf of Creditor U.S. Bank Equipment Finance 

rwoolley@askounisdarcy.com, adarcy@askounisdarcy.com 

George L. Zinkler on behalf of Creditor Balboa Capital Corporation 

gzinkler.ecf@rprslaw.com 

George L. Zinkler on behalf of Creditor De Lage Landen Financial Services, Inc. 

gzinkler.ecf@rprslaw.com 

Eric B Zwiebel, Esq on behalf of Creditor LEAF Capital Funding, LLC 

eric.zwiebel@emzwlaw.com, eservice@emzwlaw.com 

Eric B Zwiebel, Esq on behalf of Creditor PNC Equipment Finance, LLC 

eric.zwiebel@emzwlaw.com, eservice@emzwlaw.com 

Case 20-21883-SMG Doc 163 Filed 03/23/21 Page 10 of 26
11 

EXHIBIT A

(Proposed Order)

Case 20-21883-SMG Doc 163 Filed 03/23/21 Page 11 of 26
12 

UNITED STATES BANKRUPTCY COURT 

SOUTHERN DISTRICT OF FLORIDA 

FT. LAUDERDALE DIVISION 

www.flsb.uscourts.gov 

In Re: 

 Chapter 11 

WHOA NETWORKS, INC., a Florida Corp., Case No.: 20-21883-BKC-SMG 

WHOA NETWORKS, INC., a Delaware Corp. Case No.: 20-21884-BKC-SMG 

HIPSKIND TECHNOLOGY SOLUTIONS Case No.: 20-21885-BKC-SMG 

 GROUP INCORPORATED, 

PLATINUM SYSTEMS HOLDINGS, LLC, Case No.: 20-21886-BKC-SMG 

Debtors. (Jointly Administered under 

________________________________/ Case No.: 20-21883-BKC-SMG)

AGREED ORDER APPROVING STIPULATION AND GRANTING 

ADEQUATE PROTECTION AND RELATED RELIEF TO 

HEWLETT-PACKARD FINANCIAL SERVICES COMPANY 

 THIS MATTER came before the Court on the Stipulation and Joint Motion For Entry of 

Agreed Order Granting Adequate Protection and Related Relief To Hewlett-Packard Financial 

Services Company [ECF No. ____] (the “Motion”). The Court, having reviewed and considered 

the Motion, having been informed that the Debtors, Whoa Networks, LLC, (the “Whoa Florida 

Debtor”) and Hipskind Technology Solutions Group, Inc., (the “Hipskind Debtor”) two of the four 

Case 20-21883-SMG Doc 163 Filed 03/23/21 Page 12 of 26
13 

above-captioned debtors (collectively, the “Debtors”) and secured creditor, Hewlett-Packard 

Financial Services Company (“Creditor” or “HPFSC”) have agreed to the terms of this Stipulation 

and Agreed Order, and being otherwise duly advised in the premises, finds that granting the Motion 

and entering the Stipulation and Agreed Order as set forth herein is in the best interest of the 

Debtors, their creditors and all parties in interest. Accordingly, it is: 

ORDERED as follows: 

1. The Motion is GRANTED as set forth herein. 

2. The Whoa Florida Debtor and HPFSC have agreed that the Lease Agreements 

(USA3 Agreement, USA4 Agreement and USA5 Agreement as defined in the Motion) by and 

between the Whoa Florida Debtor and HPFSC relate solely to professional services and not 

equipment financing. As a result, the Whoa Florida Debtor and HPFSC have agreed that HPFSC 

shall have an allowed general unsecured claim for all purposes in these chapter 11 cases against 

the Whoa Florida Debtor in the amount of $178,078.31 (“HPFSC Whoa Florida Unsecured 

Claim”).

3. The Whoa Florida Debtor and HPFSC have further agreed that the Note 

Agreements (as defined in the Motion ) are secured financing agreements whereby HPFSC asserts 

a security interest and/or lien upon the equipment and/or other personal property more specifically 

described in Exhibit “A” attached hereto (collectively, the “HPFSC Equipment” or the 

“Collateral”)2 and has a fair market value of $75,000.00. As a result, the Hipskind Debtor and 

HPFSC have agreed that HPFSC shall have an allowed secured claim for all purposes in these 

chapter 11 cases against the Hipskind Debtor in the amount of $75,000.00 (“HPFSC Secured 

 

2 Claim #7 filed by HPFSC did not include a copy of Exhibit 1 (Financed Items) to Exhibit A to the Note Agreements. 

Accordingly, the Exhibit describing the HPFSC Equipment is attached hereto as Exhibit “B”. 

Case 20-21883-SMG Doc 163 Filed 03/23/21 Page 13 of 26
14 

Claim”) in respect of the HPFSC Equipment and a general unsecured claim in the amount of 

$198,799.29 (“HPFSC Hipskind Unsecured Claim”). 

4. In connection with the foregoing, the Parties have agreed that the Hipskind Debtor 

shall make adequate protection payments to HPFSC during the pendency of this Chapter 11 case 

in respect of the HPFSC Equipment in the amount of $1,415.34 per month (the “Adequate 

Protection Payment”) commencing March 29, 2021 and continuing on the same day of each month 

thereafter through either the effective date of a plan of reorganization in these Chapter 11 cases or 

the date of conversion or dismissal of these Chapter 11 cases. 

5. The Adequate Protection Payment was determined by fully amortizing the 

aggregate allowed HPFSC Secured Claim in the amount of $75,000.00 through equal monthly 

payments of principal and interest over 60 months (the “Term”) at an annual interest rate of 5.0%. 

6. In any plan of reorganization filed by the Hipskind Debtor or Debtors in these 

Chapter 11 cases, the Debtors agree to separately classify the HPFSC Secured Claim from all other 

classes of claims in such plan and provide for the treatment of such allowed HPFSC Secured Claim 

as set forth hereinabove, namely to continue making monthly Adequate Protection Payments to 

HPFSC for the Term, which payments, if and when paid, will satisfy the allowed HPFSC Secured 

Claim in full. Subject to such treatment being provided in any such plan, HPFSC has agreed to 

vote any and all of its allowed claims (HPFSC Secured Claim, HPFSC Unsecured Claim and 

HPFSC Whoa Florida Unsecured Claim) to accept and otherwise support such plan. 

7. The Adequate Protection Payment agreed to by the Parties shall be made by wire 

transfer pursuant to instructions to be provided by HPFSC. Any notices to HPFSC shall be sent to 

Hewlett-Packard Financial Services Company, 200 Connell Drive, Suite 5000, Berkeley Heights, 

NJ 07922. Attn: Diane Morgan, Corporate Counsel, email: diane.morgan@hpe.com. 

Case 20-21883-SMG Doc 163 Filed 03/23/21 Page 14 of 26
15 

8. Any applicable sales tax and personal property tax associated with the HPFSC 

Equipment shall be the responsibility of the Hipskind Debtor. 

9. The Hipskind Debtor agrees to maintain insurance coverage on the HPFSC 

Equipment in accordance with the terms of the HPFSC Agreement. 

10. In the event the Hipskind Debtor fails to make the Adequate Protection Payments 

as set forth herein, and such failure continues for a period of three (3) business days after the due 

date thereof, then HPFSC shall email notification of the default to Debtors counsel, Paul J. Battista, 

Esq., at pbattista@gjb-law.com. The Hipskind Debtor shall have a period of two (2) business days 

after such notice to cure such default. If the Hipskind Debtor fails to cure such default, then HPFSC 

may file an affidavit reflecting such default, the notification to cure, and the failure of the Hipskind 

Debtor to cure the default. The Hipskind Debtor shall then have three (3) business days to file a 

counter-affidavit with the Court stating that the Hipskind Debtor is not in default. If the Hipskind 

Debtor fails to file a counter-affidavit by the deadline herein, then the automatic stay imposed by 

11 U.S.C. §362 shall terminate as to the HPFSC Equipment, at which time HPFSC shall be able 

to exercise any and all rights and remedies granted to it under the Note Agreements and under 

applicable state and/or federal law. In connection therewith, HPFSC shall submit an Order to the 

Court lifting the automatic stay imposed by 11 U.S.C. §362 with respect to the HPFSC Equipment, 

which Order the Court may enter without further notice and hearing. 

11. In the event the Hipskind Debtor Chapter 11 case is dismissed or converted to a 

case under Chapter 7, then all Adequate Protection Payments made hereunder shall be applied to 

the debt in accordance with the terms set forth in the Note Agreements, and HPFSC shall be 

entitled to exercise any or all of its rights and remedies against the HPFSC Equipment or the 

Case 20-21883-SMG Doc 163 Filed 03/23/21 Page 15 of 26
16 

Hipskind as permitted pursuant to paragraph 10 above without further notice to the Hipskind 

Debtor or further order of the Court. 

# # # 

Submitted by: 

Mariaelena Gayo-Guitian, Esq. 

Counsel for Debtors-in-Possession 

Genovese Joblove & Battista, P.A. 

100 S.E. Second Street, 44th Floor 

Miami, FL 33131 

mguitian@gjb-law.com

Attorney Mariaelena Gayo-Guitian, Esq., is directed to serve a copy of this Order on all interested parties 

who did not receive a copy of the Order via CM/ECF and to file a certificate of service within two (2) days 

of the entry of the Order. 

Case 20-21883-SMG Doc 163 Filed 03/23/21 Page 16 of 26
17 

EXHIBIT B 

(Hewlett-Packard Equipment List) 

Case 20-21883-SMG Doc 163 Filed 03/23/21 Page 17 of 26
Customer Name Schedule Number Vendor Invoice # Serial # Invoice Date Man

Hipskind Technology Solutions Group, Incorporated 5398294827000002 CorpITGroupInc. 10334 7/12/2018 Dell Hipskind Technology Solutions Group, Incorporated 5398294827000002 CorpITGroupInc. 10334 7/12/2018 Dell Hipskind Technology Solutions Group, Incorporated 5398294827000002 CorpITGroupInc. 10334 7/12/2018 Dell Hipskind Technology Solutions Group, Incorporated 5398294827000002 CorpITGroupInc. 10334 7/12/2018 Dell Hipskind Technology Solutions Group, Incorporated 5398294827000002 CorpITGroupInc. 10334 7/12/2018 GeneHipskind Technology Solutions Group, Incorporated 5398294827000002 CorpITGroupInc. 10334 7/12/2018 Dell Hipskind Technology Solutions Group, Incorporated 5398294827000002 CorpITGroupInc. 10334 7/12/2018 Dell 

Case 20-21883-SMG Doc 163 Filed 03/23/21 Page 18 of 26
Category Tier Equipment Description Quantity Currency Unit Price in deal cur

NETWO ALL S3148P Network Switch, 48 10/100/1000Mbps Ports, 2 SFP+ Ports 3.00 USD 7,4NETWO ALL 1000BaseSX SFP Transceiver 1.00 USD 1NETWO ALL S3124P Network Switch, 24 10/100/1000Mbps Ports, 2 SFP+ Ports 3.00 USD 4,4PC_SE NCT1 PowerEdge R640 Rack Base, No CPU, 0 RAM, No HD 4.00 USD 18,4SOFT2 SFT2 Installation Service 1.00 USD 7,9NETWO ALL 1000BaseSX SFP Transceiver 10.00 USD 1PC_SE NCT1 PowerEdge R640 Rack Base, No CPU, 0 RAM, No HD 2.00 USD 15,9

Case 20-21883-SMG Doc 163 Filed 03/23/21 Page 19 of 26
Lease Rate Factor Equipment Location Customer PO Term Adv/Arr 

0.019960 17220 22nd Street, Suite 450, Oakbrook Terrace, IL, 60181, UNITED STATES 60 ADV 0.019960 17220 22nd Street, Suite 450, Oakbrook Terrace, IL, 60181, UNITED STATES 60 ADV 0.019960 17220 22nd Street, Suite 450, Oakbrook Terrace, IL, 60181, UNITED STATES 60 ADV 0.019960 17220 22nd Street, Suite 450, Oakbrook Terrace, IL, 60181, UNITED STATES 60 ADV 0.019960 17220 22nd Street, Suite 450, Oakbrook Terrace, IL, 60181, UNITED STATES 60 ADV 0.019960 17220 22nd Street, Suite 450, Oakbrook Terrace, IL, 60181, UNITED STATES 60 ADV 0.019960 17220 22nd Street, Suite 450, Oakbrook Terrace, IL, 60181, UNITED STATES 60 ADV 

Case 20-21883-SMG Doc 163 Filed 03/23/21 Page 20 of 26
Billing Method Family Indicator Parent Asset Extended Price in deal currency Rent Deal C

INVOICING STARTS ON ACCEPTANCE DATE Parent 22,313.58 INVOICING STARTS ON ACCEPTANCE DATE Parent 164.50 INVOICING STARTS ON ACCEPTANCE DATE Parent 13,495.98 INVOICING STARTS ON ACCEPTANCE DATE Parent 73,814.24 INVOICING STARTS ON ACCEPTANCE DATE Parent 7,940.00 INVOICING STARTS ON ACCEPTANCE DATE Parent 1,645.00 INVOICING STARTS ON ACCEPTANCE DATE Parent 31,969.42 

Case 20-21883-SMG Doc 163 Filed 03/23/21 Page 21 of 26
Customer Name Schedule Number Vendor Invoice # Serial # Invoice D

Hipskind Technology Solutions Group, Incorporated 5398294827000001 TECHNIJIAN, INC. 32720186 SSI213702QL

SSI213702PZ

3/29/2018 

Hipskind Technology Solutions Group, Incorporated 5398294827000001 TECHNIJIAN, INC. 32720186 3/29/2018 Hipskind Technology Solutions Group, Incorporated 5398294827000001 TECHNIJIAN, INC. 32720186 3/29/2018 Hipskind Technology Solutions Group, Incorporated 5398294827000001 TECHNIJIAN, INC. 32720186 3/29/2018 Hipskind Technology Solutions Group, Incorporated 5398294827000001 TECHNIJIAN, INC. 32720186 3/29/2018 Hipskind Technology Solutions Group, Incorporated 5398294827000001 TECHNIJIAN, INC. 32720186 3/29/2018 Hipskind Technology Solutions Group, Incorporated 5398294827000001 TECHNIJIAN, INC. 32720186 FOC2013U07B 3/29/2018 Hipskind Technology Solutions Group, Incorporated 5398294827000001 TECHNIJIAN, INC. 32720186 3/29/2018 Hipskind Technology Solutions Group, Incorporated 5398294827000001 TECHNIJIAN, INC. 32720186 3/29/2018 Hipskind Technology Solutions Group, Incorporated 5398294827000001 TECHNIJIAN, INC. 32720186 3/29/2018 Hipskind Technology Solutions Group, Incorporated 5398294827000001 TECHNIJIAN, INC. 32720186 3/29/2018 Hipskind Technology Solutions Group, Incorporated 5398294827000001 TECHNIJIAN, INC. 32720186 SAL 1914 CYAY 3/29/2018 Hipskind Technology Solutions Group, Incorporated 5398294827000001 TECHNIJIAN, INC. 32720186 FOX2147P15N 3/29/2018 Hipskind Technology Solutions Group, Incorporated 5398294827000001 TECHNIJIAN, INC. 32720186 3/29/2018 Hipskind Technology Solutions Group, Incorporated 5398294827000001 TECHNIJIAN, INC. 32720186 3/29/2018 Hipskind Technology Solutions Group, Incorporated 5398294827000001 TECHNIJIAN, INC. 32720186 FLM2205012Q

FLM22050172FLM220500T4FLM220503J5FLM220500UQ

3/29/2018 

Case 20-21883-SMG Doc 163 Filed 03/23/21 Page 22 of 26
Part Number Category Tier Equipment Description Qua

UCS-SP-FI48P NETWO CISCON UCS SmartPlay Select 6248UP Fabric Interconnect Switch, 32 SFP+ Ports INSTALL SOFT2 SFT2 Installation Service AP8959 NETWO CISCON Switched Power Distribution Unit, 16A, 230V GWARR SOFT MAINT Warranty GWARR SOFT MAINT Warranty UCS-CPU-E52630E PC_SE NCT1 2.20GHz Intel Xeon E5-2630v4 10-Core Processor, 25MB L3 Cache, 2133MHz FSB WS-C3850-48T-S NETWO CISCON Catalyst 3850 LAN Switch, 48 x 1Gbps Ports, 350W AC PS, IP Base SW C3850-NM-4-10G NETWO CISCON 4 Port Ethernet Network Module, 4 x 10Gbps SFP+ Ports GLC-T NETWO CISCON 1000BaseT Gigabit Ethernet SFP UCS-MR-1X322RV-A PC_SE NCT1 32GB DDR4 SDRAM DIMM, 2133MHz UCSB-MLOM-40G-03 PC_SE NCT1 Virtual Interface Card N9K-C9372PX NETWO CISCON Nexus 9300 Platform Switch, 48 11/0G SFP+ Ports, 6 40Gbps QSFP+ Ports UCS-SP-5108-AC PC_SE NCT1 UCS 5108 AC2 Blade Server Enclosure, No HDs, 8 Bays, No PS, 8 Fans SHIPPING SOFT2 SFT2 Shipping/Freight AP8959 NETWO CISCON Switched Power Distribution Unit, 16A, 230V UCSB-B200-M4-U PC_SE NCT1 Unified Computing System B200 M4 Blade Server, No CPU, 0 RAM, No HD, Upgd 

Case 20-21883-SMG Doc 163 Filed 03/23/21 Page 23 of 26
Unit Price in deal currency Lease Rate Factor Equipment Location C

8,315.00 0.019880 17220 22nd Street, Suite 450, Oakbrook Terrace, IL, 60181, UNITED STATES 

15,513.38 0.019880 17220 22nd Street, Suite 450, Oakbrook Terrace, IL, 60181, UNITED STATES 

1,579.29 0.019880 17220 22nd Street, Suite 450, Oakbrook Terrace, IL, 60181, UNITED STATES 

622.44 0.019880 17220 22nd Street, Suite 450, Oakbrook Terrace, IL, 60181, UNITED STATES 750.00 0.019880 17220 22nd Street, Suite 450, Oakbrook Terrace, IL, 60181, UNITED STATES 

1,050.00 0.019880 17220 22nd Street, Suite 450, Oakbrook Terrace, IL, 60181, UNITED STATES 5,750.00 0.019880 17220 22nd Street, Suite 450, Oakbrook Terrace, IL, 60181, UNITED STATES 1,544.00 0.019880 17220 22nd Street, Suite 450, Oakbrook Terrace, IL, 60181, UNITED STATES 

195.00 0.019880 17220 22nd Street, Suite 450, Oakbrook Terrace, IL, 60181, UNITED STATES 

1,285.00 0.019880 17220 22nd Street, Suite 450, Oakbrook Terrace, IL, 60181, UNITED STATES 1,145.00 0.019880 17220 22nd Street, Suite 450, Oakbrook Terrace, IL, 60181, UNITED STATES 

23,750.00 0.019880 17220 22nd Street, Suite 450, Oakbrook Terrace, IL, 60181, UNITED STATES 

9,926.60 0.019880 17220 22nd Street, Suite 450, Oakbrook Terrace, IL, 60181, UNITED STATES 2,200.00 0.019880 17220 22nd Street, Suite 450, Oakbrook Terrace, IL, 60181, UNITED STATES 1,579.29 0.019880 17220 22nd Street, Suite 450, Oakbrook Terrace, IL, 60181, UNITED STATES 8,830.00 0.019880 17220 22nd Street, Suite 450, Oakbrook Terrace, IL, 60181, UNITED STATES 

Case 20-21883-SMG Doc 163 Filed 03/23/21 Page 24 of 26
Adv/Arr Pay Frequency Billing Method Family Indicator Parent Asset Extended Price in d

ADV MONTHLY INVOICING STARTS ON ACCEPTANCE DATE Parent ADV MONTHLY INVOICING STARTS ON ACCEPTANCE DATE Parent ADV MONTHLY INVOICING STARTS ON ACCEPTANCE DATE Parent ADV MONTHLY INVOICING STARTS ON ACCEPTANCE DATE Parent ADV MONTHLY INVOICING STARTS ON ACCEPTANCE DATE Parent ADV MONTHLY INVOICING STARTS ON ACCEPTANCE DATE Parent ADV MONTHLY INVOICING STARTS ON ACCEPTANCE DATE Parent ADV MONTHLY INVOICING STARTS ON ACCEPTANCE DATE Parent ADV MONTHLY INVOICING STARTS ON ACCEPTANCE DATE Parent ADV MONTHLY INVOICING STARTS ON ACCEPTANCE DATE Parent ADV MONTHLY INVOICING STARTS ON ACCEPTANCE DATE Parent ADV MONTHLY INVOICING STARTS ON ACCEPTANCE DATE Parent ADV MONTHLY INVOICING STARTS ON ACCEPTANCE DATE Parent ADV MONTHLY INVOICING STARTS ON ACCEPTANCE DATE Parent ADV MONTHLY INVOICING STARTS ON ACCEPTANCE DATE Parent ADV MONTHLY INVOICING STARTS ON ACCEPTANCE DATE Parent 

Case 20-21883-SMG Doc 163 Filed 03/23/21 Page 25 of 26
Rent Deal Currency

330.60308.41

31.4012.3774.55

208.74114.31

30.6915.51

1,021.83

113.81472.15197.34

43.7431.40

877.70

Case 20-21883-SMG Doc 163 Filed 03/23/21 Page 26 of 26