52884346;1 

UNITED STATES BANKRUPTCY COURT 

SOUTHERN DISTRICT OF FLORIDA 

West Palm Beach Division 

www.flsb.uscourts.gov

In re: Chapter 11

TOOJAY’S MANAGEMENT LLC, Case No. 20-14792-EPK 

Debtor. 

/ 

DEBTOR’S EMERGENCY MOTION FOR ENTRY OF AN ORDER: 

(I) AUTHORIZING THE PAYMENT OF PRIORITY PRE-PETITION WAGES, SALARIES, 

EARNED BONUSES, AND EMPLOYEE BENEFITS; AND (II) AUTHORIZING THE 

DEBTOR TO CONTINUE THE MAINTENANCE OF EMPLOYEE PRACTICES AND 

BENEFIT PLANS AND PROGRAMS IN THE ORDINARY COURSE OF BUSINESS 

(Emergency Hearing Requested on Friday, May 1st) 

Statement of Exigent Circumstances 

The Debtor submits that a hearing on this Motion is necessary on an 

emergency “first day” basis because if the priority prepetition wages are not 

honored and paid the Debtor's employees may walk off the job or not return 

to work, causing a cessation of Debtor’s operations. The Debtor requests an 

emergency hearing in this matter to give certainty and comfort to its 

employees that payroll and other employee obligations may continue to be 

satisfied in the ordinary course. The Debtor needs the continued support of 

its employees to allow for a successful Chapter 11 reorganization. The 

Debtor's request to pay priority pre-petition wages must be heard on an 

emergency basis together with related motions to use cash collateral so the 

pre-petition wages can be funded and the Debtor can continue to operate. 

Debtor, TOOJAY’S MANAGEMENT LLC (the “Debtor”), by and through undersigned 

counsel, pursuant to 11 U.S.C. §§ 105(a), 363(b) and 507(a)(4), Federal Rule of Bankruptcy 

Procedure 6003 and Local Rules 9013-1(I)and 9075-1, files this motion (the “Motion”) seeking 

entry of an order (A) authorizing the Debtor to (i) pay Pre-Petition wages, salaries, earned 

bonuses, employee benefits and other compensation; (ii) remit withholding obligations; (iii) 

maintain employee benefit programs and continue the maintenance of employee practices and 

benefit plans and programs in the Debtor's ordinary course of business. In support of this Motion, 

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the Debtor relies upon the Declaration of Edward Maxwell Piet in Support of the Debtors’ 

Chapter 11 Petitions and First Day Motions (the “First Day Declaration”). In further support of 

this Application, the Debtor respectfully represents as follows: 

I. Jurisdiction and Venue 

1. This Court has jurisdiction over this matter pursuant to 28 U.S.C. §§ 157 and 

1334. This is a core proceeding pursuant to 28 U.S.C. § 157(b)(2). 

2. Venue is proper before this Court pursuant to 28 U.S.C. §§ 1408 and 1409. 

3. The statutory predicates for the relief sought herein are Sections 105(a), 

507(a)(4), 507(a)(5) and 541 of the Bankruptcy Code, Rule 6003 of the Federal Rules of 

Bankruptcy Procedure (the “Bankruptcy Rules”) and Local Rule 9013-1(I). 

II. Background 

4. On the date hereof (the “Petition Date”), the Debtor, and Debtor’s affiliates filed 

voluntary petitions (“Petition”) in this Court for relief under Chapter 11 of Title 11 of the United 

States Code (the “Bankruptcy Code”).1 A motion for joint administration of these Chapter 11 

cases will be filed. 

5. The Debtor is operating its businesses and managing its affairs as a debtor in 

possession. See 11 U.S.C. §§ 1107(a) and 1108. 

1

 The Debtors in these Chapter 11 Cases, along with the last four digits of each Debtors’ federal tax identification 

number, are: TooJay’s Management LLC (0443) and TJ Acquisition, LLC (1455). The following additional 

affiliates of Debtors have or will file Chapter 11 Cases (collectively, “Filing Affiliates”): TooJay’s Altamonte, 

L.L.C. (5466), TooJay’s at Dr. Phillips, L.L.C. (8342), TooJay’s Bakery & Commissary, L.L.C. (7016), TooJay’s 

Boynton Oakwood Square, L.L.C. (3583), TooJay’s Colonial, L.L.C. (6530), TooJay’s Coral Springs, L.L.C. 

(5919), TooJay’s Dania Beach, L.L.C. (2030), TooJay’s Downtown Gardens, L.L.C. (0351), TooJay’s Downtown 

Tampa, L.L.C. (5046), TooJay’s Glades, L.L.C. (3884), TooJay’s Hallandale, L.L.C. (4596), TooJay’s Jupiter, 

L.L.C. (5986), TooJay’s Lake Worth, L.L.C. (3353), TooJay’s Naples, LLC (3336), TooJay’s N Ft. Lauderdale, 

L.L.C. (8438), TooJay’s of Lake Mary, LLC (0594), TooJay’s of Ocoee, L.L.C. (9601), TooJay’s of Sarasota, 

L.L.C. (7584), TooJay’s of the Villages, L.L.C. (0798), TooJay’s of West Boca, L.L.C. (8250), TooJay’s Palm 

Beach, L.L.C. (1908), TooJay’s Plantation, L.L.C. (8882), TooJay’s Stuart, L.L.C. (4505), TooJay’s Vero, L.L.C. 

(0750), TooJay’s Villages III, L.L.C. (5254), TooJay’s VLG II, L.L.C. (2492), TooJay’s Waterford Lakes, L.L.C. 

(9363), TooJay’s Wellington Commons, L.L.C. (3967), and TooJay’s West Palm Beach, L.L.C. (4685). 

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6. For a detailed description of the Debtor and its operations, the Debtor respectfully 

refers the Court and all parties in interest to the First Day Declaration. 

III. Relief Requested 

7. The Debtor seeks entry of an order pursuant to sections 105(a), 507(a)(4), and 

363(b) of the Bankruptcy Code: (i) authorizing, but not directing, it to pay and/or honor 

prepetition employee-related obligations, including, but not limited to, prepetition wages, 

salaries, earned bonuses, medical, dental and insurance benefits, paid time off, vacation, sick and 

medical leave, (collectively, the “Prepetition Employment Obligations”), (ii) authorizing, but not 

directing, the Debtor to continue its practices, programs and policies in effect as of the Petition 

Date with respect to all Prepetition Employment Obligations. 

8. As required by Local Rule 9013-1(I)(1), this Motion, together with the attached 

schedule, Exhibit A, contain: (a) the names of the employees, (b) amount due such employees, 

(c) the amounts due to be withheld from such wages, including all applicable payroll taxes and 

related benefits, (d) the period of time for which prepetition wages and earned bonuses are due, 

(e) whether the employee is presently employed, and (f) whether any of the employees are 

insiders as defined in 11 U.S.C. § 101(31). Exhibit A indicates the names (redacted for privacy) 

and amounts due the employees, the period of time for which the wages on Exhibit A are due are 

April 20, 2020, through and including April 28, 2020. All of the employees listed on Exhibit A 

are currently employed, and there are six insiders among these employees as follows: (1) David 

Nuckles – Sr VP of Operations; (2) Brett Carper – Director of Operations; (3) Kevin Gagnon –

VP Finance; (4) Robin Bayless – VP Marketing; (5) Edward Piet – CEO and President; (6) 

Arthur Sanders – VP Human Resources. 

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9. All applicable payroll taxes and related benefits, to the extent applicable, will be 

paid concurrently with the payment of the prepetition wages and earned bonuses identified on 

Exhibits A and B to this Motion when authority to pay such wages and earned bonuses has been 

granted. See Local Rule 9013-1(I). 

IV. Payment of Employee Compensation, Withholding Obligations and Insurance Costs 

10. The Debtor utilizes the services of Paymaster, a professional employer 

organization, to manage payroll-related taxes, certain human resources functions, access to 

benefits, and other employer-related administrative functions necessary to running the Debtor's 

business. The total amount due and owing to Paymaster for wages and salaries for the 9 day 

period of time from April 20, 2020, through and including April 28, 2020, will be approximately 

$366,244.10, and the total amount due and owing for prepetition compensation bonuses is 

$109,855.84 for the period of January 1, 2020 to March 29, 2020. These amounts include (i) 

prepetition wages, salaries, earned performance bonuses, and other compensation; (ii) other 

benefits, withholdings, and reimbursements; (iii) payments made on employee benefit plans; and 

(iv) social security, income tax, and other mandated withholdings. 

A. Prepetition Wages, Salaries, Bonuses and Other Compensation 

11. As of the Petition Date, the Debtor employed approximately 290 W-2 employees 

(the “Employees”). Approximately 70 of the Employees are salaried (the “Salaried Employees”), 

and the remaining 220 Employees are hourly (the “Hourly Employees”). The Hourly Employees 

consist primarily of managers, register clerks, employees of the bakery commissary, cooks, and 

deli counter employees. The Salaried Employees consist of the Debtor’s executives, general 

managers, area directors, and catering sales department managers. The Salaried Employees and 

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the Hourly Employees are paid bi-weekly on Tuesday, with twenty-six payrolls a year, and are 

next due to be paid on May 12, 2020. 

12. The Debtor seeks authority to pay the outstanding amounts owed as of the 

Petition Date for priority accrued and unpaid wages, salaries, and fees, including amounts that 

the Debtor is required by law to withhold from Employee payroll checks in respect of federal, 

state, and local income taxes, garnishments, and Social Security and Medicare taxes and 

including associated payroll processing obligations related thereto. A pro rata accounting of 9 

days’ of prepetition payroll for the Employees is attached as Exhibit A.2

13. The Debtor also seeks authority to pay an earned performance bonus for 

approximately one-hundred and twenty (120) employees for the period of the first quarter. An 

accounting for the gross amount bonus per Employee is attached as Exhibit B (the “Earned 

Bonuses”). Store managers and bakery commissary managers are entitled to a quarterly bonus, 

based on performance, including sales, labor, cost of goods controls, that is part of their bonus 

compensation plan. The Earned Bonuses amount for each employee is based on the level of the 

managerial employee, from 5% to 15% of yearly base paid out quarterly. Typically, these 

employees’ bonuses for the first quarter are paid in April, and therefore Debtor requests authority 

to pay the earned bonuses no later than Friday, May 1, 2020. These employees have met the 

metrics for entitlement to the Earned Bonuses and their compensation is earned pursuant to their 

employment agreements with Debtor. Pursuant to Local Rule 9013-1(I)(1), Debtor states: (1) all 

of the employees for which still employed, (2) none of the employees are insiders, and (3) the 

period of time for which the compensation was earned was January 1, 2020 thru March 29, 2020. 

2

 This accounting is approximate based on the amounts owed by Debtor in the previous pay period on a pro rata 

basis. A final accounting of the amounts owed to the employees for the 9-day pay period will be determined upon 

finalization of payroll for the payroll period. 

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14. Moreover, the Debtor has sufficient funds designated to pay the payroll costs of 

its employees. The Debtor recently received a loan in the amount of approximately $6,400,000 

through the Paycheck Protection Program (“PPP”) pursuant to the title II of the Coronavirus Aid, 

Relief, and Economic Security Act (the “CARES Act.”) The PPP loan may be used for, among 

other things, (I) payroll costs; (II) costs related to the continuation of group health care benefits 

during periods of paid sick, medical, or family leave, and insurance premiums; and (III) salaries, 

commissions, or similar compensations. The Debtor intends to honor that obligation by using 

the proceeds for such purposes, and other purposes as allowed by the CARES Act. 

B. Other Benefits, Withholdings, and Reimbursements 

15. The Debtor offers its Employees other forms of compensation, including vacation 

time, paid holidays, paid sick leave, and other earned time off. These forms of compensation are 

usual, customary, and necessary if the Debtor is to retain qualified employees to operate its 

business. 

16. To become eligible to take paid vacation time, the Employee must complete one 

(1) year of continuous active employment. The length of service and job position determines an 

Employee’s amount of paid vacation (“Vacation Time”). Vacation Time ranges from 1 weeks to 

4 weeks, based on an Employee’s years of service and their date of hire, and their position. 

Actual payment to Employees for Vacation Time is based on an Employee’s years of service and 

the number of vacation days taken. Employees who resign or are terminated normally are not 

entitled to any compensation for their accrued and unused Vacation Time. 

17. After 12 months of consecutive full time employment the Employee will accrue 

four to five days of sick leave (“Sick Leave”) on a yearly basis. Employees who resign or are 

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terminated normally are not entitled to any compensation for their accrued and unused Sick 

Leave. 

18. The Debtor seeks authority to honor in the ordinary course of business all 

prepetition accrued Vacation Time, Sick Leave and any other personal leave rights of its 

Employees who continue to be employed by the Debtor after the Petition Date. The Employees 

will utilize any accrued Vacation Time and Sick Leave in the ordinary course of business. 

C. Employee Benefit Plans 

19. The Debtor offers additional benefits, including medical insurance, vision 

insurance, dental insurance, disability insurance, life insurance, and various other supplemental 

insurance (collectively, the “Benefit Plans”). The Benefit Plans are serviced by Alliant. The 

Benefit Plans are partially funded through contributions by the Debtor and Employees contribute 

to the Benefit Plans through payroll deductions. The Debtor deducts funds from Employee 

paychecks prior to plan payments in order to collect Employee contributions. 

20. The Debtor requests authority to make all payments, claims, and remittances 

related to the Benefit Plans in the ordinary course of business. 

D. Social Security, Income Taxes, and Other Withholding

21. The Debtor routinely withholds from Employee paychecks amounts that the 

Debtor is required to transmit to third parties. Examples of such withholding are garnishments, 

and/or health care payments. The Debtor believes that such withheld funds, to the extent that 

they remain in the Debtor’s possession, constitute monies held in trust and, therefore, are not 

property of the Debtor’s bankruptcy estate. The Debtor requests that its practice of directing such 

funds to the appropriate parties in the ordinary course of business be specifically authorized and 

approved by the Court out of an abundance of caution. 

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22. The Debtor's Employees would suffer hardship if they were to lose (or suffer a 

delay in receiving) their anticipated pay and benefits. The Debtor has paid its Employment 

Obligations on a current basis. Some Employment Obligations for the period immediately 

before the filing of the petition, however, have not been paid, primarily because the petition was 

filed after the Employees’ entitlements had accrued but before payment was due. 

23. The Debtor has determined that, in order to ensure that the Employees remain 

with the Debtor during its Chapter 11 case, and in order to maintain Employee morale and 

productivity and continuous service to its customers, it is necessary to pay, in the ordinary course 

of the Debtor’s businesses, the Prepetition Employment Obligations that are owed to or payable 

for the benefit of the Debtor's current Employees as set forth in this Motion. Payment of these 

amounts will help assure that the Employees to continue to work for the Debtor, thereby 

avoiding potential disruption in the Debtor's business and its service to customers, promoting the 

prospects for a successful reorganization, and, ultimately, enhancing potential recoveries for the 

Debtor’s creditors. 

V. Legal Basis and Authority for Relief 

24. As a result of the commencement of these cases, and in the absence of an order of 

the Court providing otherwise, the Debtor will be prohibited from paying or otherwise satisfying 

its Prepetition Employment Obligations described above. To maintain Employee morale at this 

critical time for the Debtor, and to minimize the personal hardship the Employees would suffer if 

prepetition employee-related obligations are not paid when due, the Debtor seeks authority to 

honor in the exercise of its business judgment such obligations, including those described above. 

25. Accordingly, pursuant to sections 105(a), 363(b) and 507(a)(4) of the Bankruptcy 

Code and the “necessity of payment” doctrine, the Debtor seeks entry of an order authorizing, 

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but not directing, the Debtor to (i) pay priority Prepetition Employment Obligations, and (ii) 

continue the practices, programs and policies in effect as of the Petition Date with respect to all 

Prepetition Employment Obligations. 

26. Relief similar to that sought herein has been granted by Courts in this District. 

See, e.g., In re Gemini Cargo Logistics, Inc. et al., Chapter 11 Case No. 08-18173-BKC-AJC 

(Bankr. S.D. Fla. June 20, 2008) (Cristol, J.); In re Tousa, Inc., et al, Chapter 11 Case No. 08-

10928-BKC-JKO (Bankr. S.D. Fla. Jan. 31, 2008) (Olson, J.); In re Gemini Cargo Logistics, Inc. 

et al., Chapter 11 Case No. 06-10870-BKC-AJC (Bankr. S.D. Fla. March 17, 2006) (Cristol, J.); 

In re Atlas Air Worldwide Holdings, Inc. et al., Chapter 11 Case No. 04-10792-BKC-RAM 

(Bankr. S.D. Fla. Feb. 10, 2004) (Mark, J.); In re Realauction.com, LLC, Chapter 11 Case No. 

13-28260-RBR (Bankr. S.D. Fla. Aug. 6, 2013) (Ray, J.); In re Worldwide Transportation 

Services, Inc., Case No. 16-11136-LMI (Bankr. S.D. Fla. Jan. 26, 2016) (Isicoff, J.); In re 

Advance Case Parts, Inc., Chapter 11 Case No. 19-14930-RBR (Bankr. S.D. Fla. April 19, 2019) 

(Ray, J.). 

27. Section 363(b)(1) of the Bankruptcy Code provides: “The trustee, after notice and 

a hearing, may use, sell, or lease, other than in the ordinary course of business, property of the 

estate.” 11 U.S.C. § 363(b)(1). 

28. Section 105(a) of the Bankruptcy Code provides: 

The court may issue any order, process, or judgment that is 

necessary or appropriate to carry out the provisions of this title. No 

provision of this title providing for the raising of an issue by a 

party in interest shall be construed to preclude the court from, sua

sponte, taking any action or making any determination necessary 

or appropriate to enforce or implement court orders or rules, or to 

prevent an abuse of process. 

 11 U.S.C. § 105(a). 

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29. Pursuant to section 507(a)(4) of the Bankruptcy Code, as amended by the 

Bankruptcy Abuse Prevention and Consumer Protection Act of 2005, each employee may be 

granted a priority claim for: 

allowed unsecured claims, but only to the extent of $13,650 for 

each individual or corporation, as the case may be, earned within 

180 days before the date of the filing of the petition or the date of 

the cessation of the debtor’s business, whichever occurs first, for – 

(A) wages, salaries, or commissions, including vacation, 

severance, and sick leave pay earned by an individual; or (B) sales 

commissions earned by an individual or by a corporation with only 

1 employee, acting as an independent contractor in the sale of 

goods or services, for the debtor in the ordinary course of the 

debtor’s business if, and only if, during the 12 months preceding 

that date, at least 75 percent of the amount that the individual or 

corporation earned by acting as an independent contractor in the 

sale of goods or services was earned from the debtor .... 

11 U.S.C. § 507(a)(4). 

30. Because all of the Prepetition Employment Obligations constitute priority claims 

pursuant to section 507(a)(4) of the Bankruptcy Code, which claims must be paid in full pursuant 

to section 1129(a)(9) of the Bankruptcy Code in order to confirm a plan of reorganization, 

payment of such obligations at this time merely affects the timing, but not the appropriateness, of 

such payments. None Employees are owed in excess of $13,650 in respect of Prepetition 

Employment Obligations earned within 180 days of the Petition Date, and the Debtor will not 

pay in excess of this amount per Employee for Prepetition Employee Obligations. 

31. The Debtor's Employees are essential to the success of its business, and thus to a 

successful reorganization. The stability of the Debtor's workforce is essential to its continued 

operations. It is therefore critical that the Debtor be permitted to continue the ordinary course 

personnel policies, programs and procedures that were in effect prior to the Petition Date. 

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32. The Eleventh Circuit has recognized and applied the doctrine of necessity in 

various cases. See, e.g., Southern Ry. Co. v. U.S. Fidelity & Guar. Co., 87 F.2d 118, 119 (5th Cir. 

1936) 3(“There is a doctrine which permits preferential payment of a common claim when 

necessary for the benefit of the estate.”) (citing Miltenberger v. Logansport R. Co., 106 U.S. 286 

(1882)). The doctrine was expanded to non-railroad debtors in a decision by Judge Learned Hand 

in Dudley v. Mealey, 147 F.2d 268, 271 (2d Cir. 1945) (holding, in a hotel reorganization case, 

that the court was not “helpless” to apply the rule to supply creditors of non-railroad debtors 

where the alternative was the cessation of operations). 

33. Today, the rationale for the necessity of payment rule – the rehabilitation of a 

debtor in reorganization cases – is “the paramount policy and goal of Chapter 11.” In re 

Ionosphere Clubs, Inc., 98 B.R. 174, 176 (Bankr. S.D.N.Y. 1989); In re Just For Feet, Inc., 242 

B.R. 821 (D. Del. 1999) (payment of prepetition claims to certain trade vendors was “essential to 

the survival of the debtor during the chapter 11 reorganization”); In re Quality Interiors. Inc., 

127 B.R. 391, 396 (Bankr. N.D. Ohio 1991) (“payment by a debtor-in-possession of pre-petition 

claims outside of a confirmed plan of reorganization is generally prohibited by the Bankruptcy 

Code,” but “[a] general practice has developed, however, where bankruptcy courts permit the 

payment of certain pre-petition claims, pursuant to 11 U.S.C. § 105, where the debtor will be 

unable to reorganize without such payment”); In re Eagle-Picher Indus., Inc., 124 B.R. 1021, 

1023 (Bankr. S.D. Ohio 1991) (court approved payment of prepetition unsecured claims of 

toolmakers as “necessary to avert a serious threat to the Chapter 11 process”); In re Adams 

Apple, Inc., 829 F.2d 1484, 1490 (9th Cir. 1987) (recognizing that allowance of “unequal 

treatment of pre-petition debts when necessary for rehabilitation ...”); In re Chateauguay Corp., 

3 This case constitutes binding Eleventh Circuit precedent. Bonner v . City of Prichard, 661 F.2d 1206, 

1209 (11th Cir. 1981) (en banc). 

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80 B.R. 279, 287 (Bankr. S.D.N.Y. 1987) (authorizing payment of prepetition worker’s 

compensation claims on grounds that the fundamental purpose of reorganization and equity 

powers of bankruptcy courts “is to create a flexible mechanism that will permit the greatest 

likelihood of survival of the debtor and payment of creditors in full or at least proportionately”); 

see also 2 Collier on Bankruptcy, ¶ 105.04[5][a] (15th ed. Rev. 2004). 

34. The Debtor further submits that the withholding obligations do not constitute 

property of its estate and principally represent employee earnings that governments (in the case 

of taxes), Employees (in the case of voluntary withholding obligations), and judicial authorities 

(in the case of involuntary withholding obligations), have designated for deduction from 

Employee paychecks. The failure to transfer these withheld funds could result in hardship to 

certain employees. 

35. Further, the Debtor submits that with respect to the wage-related taxes that 

constitute “trust fund” taxes, the payment of such taxes will not prejudice other creditors of the 

Debtor's estate given that the relevant taxing authorities would have a priority claim under 

section 507(a)(8) of the Bankruptcy Code in respect of such obligations. 

36. The Debtor’s Employees are essential to operate its business. For this reason, and 

the reasons set forth above, the request to pay Prepetition Employment Obligations and to 

continue the ordinary course personnel policies, programs and procedures that were in effect 

prior to the Petition Date is justified under the foregoing authorities, as well as section 105(a) of 

the Bankruptcy Code. 

VI. Reservation of Debtor’s Rights

37. Nothing contained herein is intended or should be construed as an admission as to 

the validity of any claim against the Debtor, a waiver of the Debtor's rights to dispute any claim, 

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or an approval or assumption of any agreement, contract, or lease under Section 365 of the 

Bankruptcy Code. Likewise, if this Court grants the relief sought herein, any payment made 

pursuant to the Court’s order is not intended and should not be construed as an admission as to 

the validity of any claim or a waiver of the Debtor's rights to subsequently dispute such claim. 

Finally, this motion is without prejudice to the Debtor’s right to seek relief under Sections 1113 

and 1114 of the Bankruptcy Code. 

WHEREFORE, for all of the foregoing reasons, the Debtor respectfully requests entry 

of an order pursuant to sections 105(a), 507(a)(4), and 363(b) of the Bankruptcy Code: (i) 

authorizing, but not directing, the Debtor to pay and/or honor Prepetition Employment 

Obligations; and (ii) authorizing, but not directing, the Debtor to continue its practices, programs 

and policies in effect as of the Petition Date with respect to all Prepetition Employment 

Obligations. 

Dated: April 29, 2020 Respectfully Submitted, 

AKERMAN LLP 

Las Olas Centre II, Suite 1600 

350 East Las Olas Boulevard 

Fort Lauderdale, Florida 33301 

Tel: (954) 463-2700 

Fax: (954) 463-2224 

Proposed Attorneys for Debtors-in-Possession

 By: /s/ Amanda Klopp 

Michael I. Goldberg, Esq. 

Florida Bar No. 886602 

michael.goldberg@akerman.com

Eyal Berger, Esq. 

Florida Bar No. 11069 

eyal.berger@akerman.com

Amanda Klopp, Esq. 

Florida Bar No. 124156 

amanda.klopp@akerman.com

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CERTIFICATE OF SERVICE 

I HEREBY CERTIFY that a true and correct copy of the foregoing was served this 29th

day of April, 2020 via CM/ECF to all parties listed on the below service list, and a separate 

certificate of service on all other parties will be filed with the Court. 

AKERMAN LLP 

Las Olas Centre II, Suite 1600 

350 East Las Olas Boulevard 

Fort Lauderdale, Florida 33301 

Tel: (954) 463-2700 

Fax: (954) 463-2224 

Proposed Attorneys for Debtors-in-Possession

 By: Amanda Klopp, Esq.

Michael I. Goldberg, Esq. 

Florida Bar No. 886602 

michael.goldberg@akerman.com

Eyal Berger, Esq. 

Florida Bar No. 11069 

eyal.berger@akerman.com

Amanda Klopp, Esq. 

Florida Bar No. 124156 

amanda.klopp@akerman.com

SERVICE LIST 

20-14792-EPK Notice will be electronically mailed to: 

Michael I Goldberg, Esq on behalf of Debtor TooJay's Management LLC 

michael.goldberg@akerman.com, charlene.cerda@akerman.com 

Office of the US Trustee 

USTPRegion21.MM.ECF@usdoj.gov 

Case 20-14792-EPK Doc 10 Filed 04/30/20 Page 14 of 24
EXHIBIT A 

Case 20-14792-EPK Doc 10 Filed 04/30/20 Page 15 of 24
Last, First Name Record Gross PST Record

OASDI Amount (ER)

PST Record

Medicare

Amount (ER)

PST Record

Federal

Unemployment Tax

Amount (ER)

PST Record

ER SUTA

Florida Amount (ER)

PST Record

Cigna HSA-OAP

Pretax Amount (ER)

PST Record

Cigna OAP Pretax

Amount (ER)

PST Record

Dental Pretax

Amount (ER)

PST Record

VB - Basic

Essential Amount

(ER)

Admin Fee

R , Audrey $1,333.82 $75.50 $17.66 $122.03 $4.04 $1.25C , Peter $2,044.29 $104.31 $24.40 $275.94 $6.36 $1.25H , David $2,192.36 $120.71 $28.23 $217.00 $4.40 $1.25B , Kimberly $2,145.00 $118.05 $27.61 $220.53 $3.87 $1.25W , Timothy $1,858.97 $108.45 $25.36 $104.55 $4.04 $1.25H , Heather $2,024.77 $116.05 $27.14 $104.55 $4.04 $1.25U Salvatore $1,436.27 $73.83 $17.26 $217.00 $4.40 $1.25S Nadine $710.76 $44.07 $10.30 $5.10 $1.25G , Raymond $1,700.20 $83.06 $19.42 $290.97 $6.36 $1.25R , Stephen $1,709.44 $103.38 $24.18 $1.25J Alcide $743.94 $46.12 $10.79 $1.25J , Romial $895.28 $55.51 $12.98 $1.25D , Wilson $948.62 $58.81 $13.76 $1.25P , Michael $2,024.77 $106.49 $24.90 $217.00 $4.40 $1.25G , Shaun $2,024.03 $105.49 $24.67 $325.95 $6.36 $1.25J , Lourguens $911.94 $56.54 $13.23 $5.10 $1.25M , Greg $1,780.32 $94.24 $22.04 $202.18 $4.40 $1.25B , Kevin $1,840.00 $111.10 $25.98 $122.03 $4.04 $1.25W Mark $564.79 $35.02 $8.19 $5.10 $1.25F , Hector $1,698.48 $90.95 $21.27 $243.08 $4.40 $1.25C , John $2,288.23 $135.06 $31.59 $104.55 $4.04 $1.25N David $4,046.92 $230.39 $53.88 $290.97 $6.36 $1.25A , Pierre $799.08 $49.54 $11.59 $5.10 $1.25D , James $2,330.55 $129.82 $30.36 $210.09 $3.87 $1.25S , Harold $739.60 $45.86 $10.73 $1.25C , Irene $334.35 $20.73 $4.85 $0.66 $0.26 $1.25W

William $1,572.53 $85.23 $19.93 $311.13 $6.36 $1.25

U , Wichzert $1,129.39 $70.02 $16.37 $1.25P Adens $785.77 $48.71 $11.40 $1.25M , Charles $733.52 $45.48 $10.64 $1.25S , Anthony $2,509.32 $145.53 $34.03 $235.34 $3.87 $1.25F , Jean $844.73 $52.37 $12.25 $1.25S , Yvon $1,742.96 $99.86 $23.36 $235.34 $3.87 $1.25R Fransisco $273.65 $16.97 $3.97 $1.25J , Jean $965.46 $59.86 $14.00 $1.25S , Junior $693.10 $42.97 $10.05 $1.25K , Eitan $708.00 $43.90 $10.27 $1.25D Marie $663.06 $41.11 $9.61 $1.25J , Louigens $1,387.34 $86.02 $20.12 $1.25G , Jerry $2,279.02 $126.08 $29.49 $217.00 $4.40 $1.25H , Kevin $132.75 $8.23 $1.93 $1.25B , James $1,650.02 $94.05 $21.99 $235.34 $3.87 $1.25P Laura $1,049.42 $65.07 $15.22 $1.25W Maria $1,314.35 $81.49 $19.05 $1.25S , Lesley $1,198.71 $74.32 $17.38 $1.25C Christopher $1,653.82 $23.65 $6.36 $1.25R , Jean $1,549.29 $86.81 $20.31 $235.34 $3.87 $1.25F Josephine $860.08 $53.32 $12.47 $1.25A Nicolas $1,923.77 $107.00 $25.03 $311.13 $6.36 $1.25M John $2,003.57 $124.22 $29.05 $1.25L , Brian $810.61 $50.26 $11.76 $1.25T , Jennifer $1,939.40 $116.27 $27.19 $122.03 $4.04 $1.25A Jessica $1,367.97 $77.41 $18.10 $104.55 $4.04 $1.25

Case 20-14792-EPK Doc 10 Filed 04/30/20 Page 16 of 24
G Debra $1,418.13 $87.93 $20.56 $1.25

R , Robert $860.60 $53.36 $12.48 $5.10 $1.25L Dubre $1,406.54 $87.21 $20.39 $1.25E , Inna $1,331.69 $67.89 $15.88 $210.09 $3.87 $1.25J , Victoria $1,226.62 $76.05 $17.78 $1.25L Miranda $1,195.56 $74.13 $17.33 $1.25T Robert $1,806.65 $96.75 $22.63 $325.95 $6.36 $1.25S Ardian $1,523.41 $91.54 $21.41 $122.03 $4.04 $1.25B , Courtney $2,034.65 $99.58 $23.29 $290.97 $6.36 $1.25O Monica $46.77 $2.90 $0.67 $1.25B , Larry $1,532.57 $88.21 $20.63 $104.55 $4.04 $1.25B Evan $1,995.14 $123.69 $28.93 $1.25C , Frances $1,230.60 $76.30 $17.84 $1.25P Anthony $1,513.17 $93.82 $21.94 $1.25S , Kimberly $698.98 $43.34 $10.14 $1.25M , Casey $585.05 $36.27 $8.48 $1.25C , Kathleen $1,672.11 $94.55 $22.12 $89.74 $4.04 $1.25W , David $489.81 $30.37 $7.11 $1.25P Jennifer $1,357.96 $73.48 $17.19 $1.25J , Madsen $1,630.20 $94.26 $22.05 $104.55 $4.04 $1.25R , Dianna $1,161.26 $62.44 $14.61 $89.74 $4.04 $1.25S , Christopher $2,712.21 $151.15 $35.35 $235.34 $3.87 $1.25I , Perry $1,771.50 $78.75 $24.90 $122.03 $4.04 $1.25N Nicole $1,193.21 $71.24 $16.66 $122.03 $1.25J , Clayton $989.50 $61.35 $14.35 $1.25W , Lisa $1,010.14 $62.63 $14.65 $3.48 $1.39 $1.25C , Wilfrid $171.14 $10.61 $2.48 $1.03 $0.41 $1.25A , Jennell $1,611.64 $80.49 $18.82 $217.00 $4.40 $1.25T , Leclerc $540.15 $33.49 $7.83 $1.25A , Robin $1,666.73 $82.82 $19.37 $290.97 $6.36 $1.25D Brian $1,650.93 $95.55 $22.35 $104.55 $4.04 $1.25S , Edward $1,189.86 $73.77 $17.26 $1.25C , Brett $3,438.55 $204.81 $47.90 $243.08 $4.40 $1.25D , Kevin $1,658.05 $93.39 $21.84 $104.55 $4.04 $1.25J , William $2,293.47 $126.54 $29.59 $217.00 $6.36 $1.25A , Josclyn $632.01 $39.19 $9.16 $1.25P , Dameon $1,882.05 $91.96 $21.51 $290.97 $6.36 $1.25R , Stephen $1,459.18 $68.91 $16.11 $210.09 $3.87 $1.25L , Jillian $1,136.99 $70.49 $16.49 $5.10 $1.25L Braydon $699.36 $43.35 $10.14 $1.25N , Cheryl $2,293.47 $126.06 $29.48 $202.18 $4.40 $1.25J , Jean $964.10 $59.77 $13.98 $5.10 $1.25S , Saint Obert $601.57 $37.30 $8.72 $1.25A , Chasity $1,629.69 $94.23 $22.04 $104.55 $4.04 $1.25H , Holly $1,238.36 $67.80 $15.86 $235.34 $3.87 $1.25S , Laurie $1,134.09 $60.42 $14.13 $220.53 $3.87 $1.25D , Shawn $1,501.53 $73.01 $17.07 $290.97 $4.40 $1.25C Tim $1,484.05 $88.11 $20.61 $107.22 $4.04 $1.25H Danny $618.77 $38.36 $8.97 $5.10 $1.25H Elizabeth $770.68 $47.78 $11.18 $5.10 $1.25F , Eveline $601.47 $37.29 $8.72 $1.25G , Ryan $1,176.46 $69.96 $16.36 $122.03 $4.04 $1.25J Joseph $130.16 $8.07 $1.89 $0.78 $0.31 $1.25M Megan $2,150.69 $129.36 $30.25 $122.03 $4.04 $1.25P , Robbin $745.87 $46.24 $10.82 $5.10 $1.25J , Martino $213.08 $13.21 $3.09 $1.25C , Donna $71.81 $4.45 $1.04 $0.43 $0.17 $1.25

Case 20-14792-EPK Doc 10 Filed 04/30/20 Page 17 of 24
H Matthew $1,691.62 $97.15 $22.72 $89.74 $4.04 $1.25

K , Deborah $1,135.47 $70.40 $16.47 $1.25R , Jules $351.82 $21.81 $5.10 $2.11 $0.85 $1.25N , Scott $776.40 $48.14 $11.25 $5.10 $1.25U , Rachel $1,327.60 $82.32 $19.25 $5.10 $1.25K , Amanda $558.70 $34.64 $8.10 $1.25V , Michael $1,373.75 $85.17 $19.92 $1.25L , Kimberly $729.59 $45.24 $10.58 $1.25S , Felipe $439.64 $27.26 $6.38 $0.08 $0.03 $1.25C , Donnann $1,518.88 $86.77 $20.29 $104.55 $4.04 $1.25H , Sean $1,647.98 $101.92 $23.84 $4.04 $1.25J Clint $1,299.41 $65.89 $15.41 $210.09 $3.87 $1.25W La Shia $1,492.30 $85.71 $20.05 $104.55 $4.04 $1.25K , Thurston $1,148.16 $71.18 $16.65 $1.25F Francis $1,327.55 $82.31 $19.25 $1.25C , Emily $690.04 $42.78 $10.00 $1.25R George $1,114.38 $62.29 $14.56 $104.55 $4.04 $1.25B , Montraveious $528.97 $32.79 $7.67 $0.18 $0.07 $1.25B Joseph $1,808.14 $91.66 $21.44 $290.97 $6.36 $1.25G , Kevin $3,576.16 $201.41 $47.10 $325.95 $6.36 $1.25H , Jacquelyn $725.00 $44.95 $10.52 $1.25C , Lamontic $669.64 $41.52 $9.71 $1.25M , Nancy $1,829.73 $112.04 $26.21 $6.36 $1.25M , Yzole $764.34 $47.39 $11.08 $1.25C , Demetrius $906.48 $56.20 $13.14 $1.25M , Raul $1,540.63 $73.01 $17.08 $290.97 $6.36 $1.25P , Lisa $467.57 $28.99 $6.78 $2.81 $1.12 $1.25L , Tiffany $606.94 $37.63 $8.80 $1.53 $0.61 $1.25B , Robin $3,296.60 $197.13 $46.10 $122.03 $4.04 $1.25Q Amy $1,729.45 $93.96 $21.98 $311.13 $6.36 $1.25S , Steven $1,232.98 $76.44 $17.87 $1.25B Amanda $1,789.19 $110.93 $25.94 $1.25J , Norman $1,476.89 $76.35 $17.85 $217.00 $4.40 $1.25K , Michael $501.58 $31.10 $7.27 $3.01 $1.21 $1.25C , Christina $1,565.32 $89.07 $20.83 $235.34 $3.87 $1.25B , Shawn $5.10 $1.25M Robert $1,252.43 $77.65 $18.16 $1.25K , Laura $401.60 $24.90 $5.82 $2.20 $0.88 $1.25V , Justin $781.33 $48.45 $11.32 $5.10 $1.25P , Alexander $1,316.90 $81.65 $19.09 $5.10 $1.25L , Abigail $1,650.16 $86.36 $20.20 $325.95 $6.36 $1.25L , Willie $529.21 $32.81 $7.67 $1.25V , Gregory $692.65 $39.57 $9.25 $122.03 $4.04 $1.25R , Dee Dee $1,637.10 $101.50 $23.74 $1.25R , Crischailie $460.51 $28.55 $6.68 $1.25H , Nancy $657.17 $40.75 $9.53 $5.10 $1.25B , Judith $3,211.23 $196.12 $45.86 $122.03 $4.04 $1.25F , Taylor $1,176.61 $72.95 $17.06 $1.25C Robin $76.06 $4.72 $1.10 $0.46 $0.18 $1.25J Kemberlee $92.35 $5.73 $1.34 $0.55 $0.22 $1.25J , Darling $44.45 $2.75 $0.64 $1.25A , Matthew $1,628.46 $97.06 $22.70 $122.03 $4.04 $1.25L , Deborah $1,751.79 $98.57 $23.05 $235.34 $3.87 $1.25H , Danielle $1,564.44 $90.19 $21.09 $104.55 $4.04 $1.25M , Jennifer $1,194.16 $70.26 $16.43 $122.03 $4.04 $1.25E Heidi $135.24 $8.38 $1.96 $0.81 $0.33 $1.25B , James $578.74 $35.88 $8.39 $5.10 $1.25

Case 20-14792-EPK Doc 10 Filed 04/30/20 Page 18 of 24
B Tanner $481.76 $29.87 $6.98 $1.25

K , Tina $1,208.71 $66.14 $15.47 $104.55 $4.04 $1.25E , Christopher $1,870.38 $95.45 $22.32 $290.97 $6.36 $1.25E , Timothy $1,195.28 $74.11 $17.33 $1.25O Joseph $415.64 $25.77 $6.03 $2.49 $1.00 $1.25G , Jacques $873.20 $46.08 $10.78 $235.34 $3.87 $1.25L , Chelsea $906.90 $56.23 $13.15 $1.25V , William $1,780.32 $110.30 $25.80 $1.25B , Michael $1,054.00 $57.54 $13.46 $89.74 $4.04 $1.25L , Aaron $1,712.76 $94.84 $22.18 $325.95 $6.36 $1.25S Patrick $1,493.61 $85.80 $20.07 $104.55 $4.04 $1.25C , Rosilene $1,001.52 $62.09 $14.52 $1.57 $0.63 $1.25V , Ashley $903.40 $9.67 $210.09 $3.87 $1.25R , Labranya $783.13 $48.55 $11.36 $1.25C , Nicole $175.86 $10.90 $2.55 $1.25W , Andrew $1,605.00 $99.51 $23.27 $1.25S , Jessica $84.68 $5.25 $1.23 $0.51 $0.21 $1.25B , Terry $490.41 $30.41 $7.11 $1.89 $0.76 $1.25H Willie $2,084.49 $123.50 $28.88 $107.22 $4.04 $1.25P Edward $6,743.59 $402.98 $94.25 $325.95 $6.36 $1.25M , Abbygayle $850.41 $52.72 $12.33 $1.25C , Michelle $2,440.08 $148.30 $34.68 $122.03 $4.04 $1.25S , Monica $263.72 $16.35 $3.82 $5.10 $1.25E , Skyla-kim $1,208.19 $74.91 $17.52 $1.25K , Karl $1,511.17 $86.89 $20.32 $104.55 $4.04 $1.25S , Richard $2,067.33 $121.37 $28.39 $104.55 $4.04 $1.25D , George $1,179.60 $68.64 $16.05 $122.03 $4.04 $1.25H , Nicole $1,285.87 $79.73 $18.64 $1.25L , Jason $565.94 $35.09 $8.20 $0.48 $0.19 $1.25T , Tabitha $862.71 $49.91 $11.67 $122.03 $4.04 $1.25S , Stephanie $1,729.29 $104.31 $24.40 $122.03 $4.04 $1.25J , Moliere $84.94 $5.26 $1.23 $1.25P Edward $372.36 $23.09 $5.40 $1.25C , John $534.48 $33.14 $7.75 $1.25M , Sean $5.10 $1.25M , Geoffrey $928.85 $54.68 $12.78 $122.03 $4.04 $1.25G Mark $1,341.38 $83.16 $19.45 $1.25S , Arthur $3,335.23 $205.83 $48.14 $4.40 $1.25K r, Rebecca $255.61 $15.85 $3.71 $1.53 $0.62 $1.25W , Edward $2,010.75 $124.67 $29.16 $1.25B , Ryan $1,792.44 $90.61 $21.19 $290.97 $6.36 $1.25H , Patricia $428.70 $26.58 $6.21 $5.10 $1.25B , Mark $1,651.63 $87.73 $20.51 $210.09 $3.87 $1.25F Enrique $44.48 $2.76 $0.64 $1.25D Adam $2,205.94 $119.44 $27.93 $325.95 $6.36 $1.25V Marissa $720.14 $44.65 $10.44 $1.25W , Bradley $259.07 $16.06 $3.76 $1.55 $0.62 $1.25A Louis $1,742.32 $108.02 $25.26 $1.25M , Justin $1,599.52 $77.73 $18.18 $275.94 $6.36 $1.25J , Lori $1,736.03 $99.91 $23.36 $89.74 $4.04 $1.25K , Mark $1,479.75 $83.55 $19.54 $89.74 $3.87 $1.25S , Sean $1,413.88 $80.85 $18.91 $104.55 $4.04 $1.25B Joel $1,140.16 $70.69 $16.53 $1.25C , Jennifer $1,842.80 $107.45 $25.13 $104.55 $4.04 $1.25M , Francisco $316.29 $19.61 $4.58 $1.25K , Claudia $445.43 $27.62 $6.46 $2.67 $1.07 $1.25S , Deaunte $1,213.53 $64.54 $15.09 $220.53 $6.36 $1.25

Case 20-14792-EPK Doc 10 Filed 04/30/20 Page 19 of 24
H , Shelly $616.68 $38.24 $8.94 $1.21 $0.48 $1.25

S , Jennifer $829.93 $51.45 $12.03 $5.10 $1.25B Taylor $686.69 $42.57 $9.96 $1.25F , Shanece $560.39 $34.74 $8.13 $1.25D , Monica $971.04 $60.21 $14.09 $1.25G , Scott $1,166.26 $68.41 $16.00 $107.22 $4.04 $1.25A Jason $636.54 $39.46 $9.23 $1.25P , Adiel $716.99 $44.45 $10.40 $1.25C Philip $2,034.65 $122.24 $28.59 $107.22 $4.04 $1.25S , Catherine $816.14 $50.60 $11.83 $1.25R , Stefon $658.58 $40.83 $9.55 $1.25F , Joe Robert $1,249.64 $77.48 $18.12 $1.25B , Nicole $1,426.52 $81.71 $19.11 $104.55 $4.04 $1.25W , Sevren $1,764.09 $109.37 $25.58 $1.25P Kevin $651.74 $40.41 $9.45 $1.25P Brian $1,104.93 $68.26 $15.96 $4.04 $1.25T , Karen $1,155.60 $63.67 $14.89 $235.34 $3.87 $1.25S , Brian $1,814.07 $103.72 $24.25 $89.74 $4.40 $1.25H , Timothy $538.32 $33.38 $7.80 $1.25C Christopher $702.48 $28.88 $6.75 $210.09 $3.87 $1.25S Catrina $1,093.63 $67.81 $15.86 $1.25Z , John $1,229.90 $61.86 $14.46 $217.00 $1.25W , Jason $760.69 $47.16 $11.03 $1.75 $0.70 $1.25B , Darryl $1,629.69 $99.64 $23.30 $6.36 $1.25C Robert $1,717.15 $102.96 $24.08 $122.03 $4.04 $1.25G John $1,335.53 $82.80 $19.36 $1.25C , Travis $1,362.13 $74.91 $17.52 $220.53 $3.87 $1.25D Bryan $220.41 $13.66 $3.20 $1.12 $0.45 $1.25S , Shane $657.16 $40.74 $9.53 $1.25C Vicki $1,173.51 $72.76 $17.02 $1.25R Megan $1,347.24 $76.80 $17.96 $104.55 $4.04 $1.25P , Betty $1,432.15 $83.82 $19.61 $122.03 $4.04 $1.25W Jared $1,092.51 $64.55 $15.10 $122.03 $4.04 $1.25L , Agustina $179.24 $11.11 $2.60 $1.08 $0.43 $1.25D Wesley $736.50 $45.67 $10.68 $1.25G , Arty $1,849.64 $111.70 $26.12 $122.03 $4.04 $1.25W David $1,619.80 $92.38 $21.60 $235.34 $3.87 $1.25A Kyrcee $686.91 $42.59 $9.96 $1.25T , Michelle $666.02 $41.29 $9.66 $1.25S , Jason $383.27 $23.77 $5.56 $1.25B , Nathaniel $1,135.34 $62.82 $14.69 $4.35 $1.74 $104.55 $4.04 $1.25C , Ashley $694.75 $43.08 $10.07 $1.25M James $1,178.16 $68.75 $16.08 $107.22 $4.04 $1.25P , Aaron $1,851.93 $111.20 $26.01 $122.03 $4.40 $1.25L Stephen $2,119.83 $115.84 $27.09 $217.00 $6.36 $1.25D , Jonathan $1,492.30 $92.52 $21.64 $1.25S , Frederick $2,992.70 $160.81 $37.61 $290.97 $6.36 $1.25B , Jenifer $1,140.44 $64.59 $15.11 $1.25J , Harripersaud $534.36 $33.13 $7.75 $2.44 $0.98 $1.25J , Emmanuel $590.72 $36.63 $8.57 $1.25C , Rachel $488.82 $30.31 $7.09 $1.25K , James $1,586.63 $90.65 $21.20 $89.74 $4.04 $1.25B , Tucker $1,132.54 $62.16 $14.54 $235.34 $3.87 $1.25S , Arturo $1,363.38 $70.13 $16.40 $217.00 $1.25R , Robbin $1,708.78 $104.54 $24.45 $6.36 $1.25F , Windsor $356.82 $22.12 $5.17 $2.14 $0.85 $1.25E Debra $1,320.60 $77.12 $18.04 $107.22 $6.36 $1.25

Case 20-14792-EPK Doc 10 Filed 04/30/20 Page 20 of 24
H , Mariana $1,520.06 $94.25 $22.04 $1.25

J , Rhode $687.49 $42.62 $9.96 $1.25H , Blake $275.41 $17.08 $3.99 $1.25B Selth $662.25 $41.06 $9.60 $1.25C , James $852.68 $52.86 $12.36 $1.25Z Aileen $557.81 $34.58 $8.09 $1.35 $0.54 $1.25E , Eduardo $1,801.80 $110.32 $25.80 $3.87 $1.25R , Dawn $1,545.00 $88.31 $20.65 $89.74 $1.25S , Laurie $1,185.23 $73.48 $17.19 $1.25F r, Hasheen $568.36 $35.24 $8.24 $1.25F , Melissa $1,394.10 $86.03 $20.12 $1.25C , Hollis $1,788.55 $110.30 $25.79 $1.25G , Eustace $1.25B Timothy $2,345.77 $135.72 $31.74 $89.74 $4.04 $1.25M , Travis $1,244.43 $76.83 $17.97 $4.04 $1.25H , Livingston $2,037.34 $125.99 $29.47 $4.04 $1.25G Kayla $288.71 $17.90 $4.19 $1.73 $0.69 $1.25K Thomas $1,079.17 $66.91 $15.65 $6.48 $2.59 $1.25H Karen $12.99 $0.81 $0.19 $0.08 $0.03 $1.25T , Wendy $664.19 $41.18 $9.63 $3.99 $1.59 $1.25B Wyatt $1,092.21 $67.71 $15.84 $6.55 $2.62 $1.25G Sara $863.58 $53.54 $12.53 $5.18 $2.07 $1.25

$366,244.10 $21,230.14 $5,004.85 $72.25 $28.92 $10,857.49 $10,994.94 $583.78 $107.05 $378.66

Case 20-14792-EPK Doc 10 Filed 04/30/20 Page 21 of 24
EXHIBIT B 

Case 20-14792-EPK Doc 10 Filed 04/30/20 Page 22 of 24
Row Labels Sum of Reg HoursSum of Overtime hours Total Hours Bonus Amount OT Premium Total Bonus

A Louis 472.68 174.09 646.77 297.88 40.09 $337.97

A Jessica 560 193.02 753.02 497.49 63.76 $561.25

A Matthew 560 217 777 312.5 43.64 $356.14

A Robin 737.27 737.27 1645.31 0 $1,645.31

A Nicolas 766.7 766.7 1412.06 0 $1,412.06

B Angela 157.22 157.22 0 $0.00

B Amanda 560 212.28 772.28 243.34 33.44 $276.78

B Nicole 560 193.5 753.5 637.41 81.84 $719.25

B Courtney 825.94 825.94 2575 0 $2,575.00

B Darryl 688.43 688.43 825 0 $825.00

B Ryan 560 192.8 752.8 750 96.04 $846.04

B James 560 158.94 718.94 506.47 55.98 $562.45

B rMark 763.35 763.35 2090.25 0 $2,090.25

B Evan 718.69 718.69 2150 0 $2,150.00

B eJoseph 732.83 732.83 2288.34 0 $2,288.34

B Kevin 554.83 129.16 683.99 1141.68 107.79 $1,249.47

B Michael 560 186.2 746.2 312.5 38.99 $351.49

B Larry 560 181.24 741.24 907.37 110.93 $1,018.30

C Jennifer 541.1 204.17 745.27 0 $0.00

C Michelle 560 224.78 784.78 688.4 98.59 $786.99

C Christopher 538.44 120.6 659.04 0 $0.00

C Jeffrey 320 109.94 429.94 0 $0.00

C Kathleen 808.7 808.7 2116.19 0 $2,116.19

C Donnann 753.54 753.54 1922.25 0 $1,922.25

C Christina 500.53 204.26 704.79 250.81 36.34 $287.15

C John 703.71 703.71 2895.93 0 $2,895.93

C Robert 560 281.2 841.2 0 $0.00

C Christopher 618.49 618.49 2093.03 0 $2,093.03

C Travis 560 172.99 732.99 0 $0.00

C Peter 660.84 660.84 2018.01 0 $2,018.01

C Tim 520 167.52 687.52 0 $0.00

D Cynthia 400 137.65 537.65 0 $0.00

D Brian 694.83 41.22 736.05 1726.99 48.36 $1,775.35

D Adam 560 209.46 769.46 285.8 38.9 $324.70

D Kevin 560 226.81 786.81 585.2 84.35 $669.55

D George 560 233.04 793.04 519.2 76.29 $595.49

D James 732.64 732.64 2949.49 0 $2,949.49

E Timothy 560 193.16 753.16 336.27 43.12 $379.39

E Inna 560 239.03 799.03 321.78 48.13 $369.91

E Skyla-kim 560 216.23 776.23 0 $0.00

E Christopher 560 236.22 796.22 1245.47 184.75 $1,430.22

F Francis 557.27 181.57 738.84 354.63 43.58 $398.21

F Hector 546.66 128.94 675.6 0 $0.00

F Tony 280 88.06 368.06 0 $0.00

G John 547.18 191.39 738.57 1034.98 134.1 $1,169.08

G Shaun 766.5 766.5 1998.02 0 $1,998.02

G Arty 560 216.08 776.08 680.63 94.75 $775.38

G Raymond 699.01 699.01 1678.34 0 $1,678.34

G Jerry 771.11 771.11 2249.74 0 $2,249.74

G Scott 560 289.03 849.03 0 $0.00

G Mark 548.65 155.71 704.36 97.49 10.78 $108.27

H Sean 560 155.32 715.32 251.32 27.29 $278.61

H Matthew 727.47 727.47 855.17 0 $855.17

I Perry 553.48 181.57 735.05 622.36 76.87 $699.23

J Lori 560 215.99 775.99 516.01 71.81 $587.82

J Madsen 560 322.04 882.04 967.55 176.63 $1,144.18

J Clint 560 246.89 806.89 700 107.09 $807.09

J Norman 360 135.34 495.34 357.42 48.83 $406.25

K Mark 560 194.5 754.5 228.31 29.43 $257.74

K Tina 510.28 151.02 661.3 1050 119.89 $1,169.89

K Karl 762.58 762.58 1810.5 0 $1,810.50

L Deborah 780.78 780.78 2135.78 0 $2,135.78

L Aaron 722.13 722.13 1702.3 0 $1,702.30

M Justin 757.31 757.31 1740.91 0 $1,740.91

M Greg 774.9 774.9 775.08 0 $775.08

M Megan 559.39 162.94 722.33 1062 119.78 $1,181.78

M Robert 551.12 110.73 661.85 617.76 51.68 $669.44

M Raul 560 223.45 783.45 745.4 106.3 $851.70

M Jennifer 560 200.99 760.99 306.02 40.41 $346.43

M Nancy 559 211.27 770.27 724.74 99.39 $824.13

M Geoffrey 560 232.1 792.1 0 $0.00

N Nicole 560 170.33 730.33 449.85 52.46 $502.31

P Brian 550.44 146.06 696.5 0 $0.00

Case 20-14792-EPK Doc 10 Filed 04/30/20 Page 23 of 24
P Michael 659.05 659.05 2562.28 0 $2,562.28

P eDameon 687.4 687.4 2381.88 0 $2,381.88

Q Amy 732.24 732.24 2188.75 0 $2,188.75

R Stephen 680.5 680.5 1250 0 $1,250.00

R Jean 480 192.3 672.3 427.61 61.16 $488.77

R George 560 155.79 715.79 0 $0.00

R Stephen 560 243.66 803.66 866.05 131.29 $997.34

R Dee Dee 708.4 708.4 1207 0 $1,207.00

R Megan 542.51 196.27 738.78 0 $0.00

S Deaunte 560 249.35 809.35 317.09 48.85 $365.94

S Richard 798.83 798.83 1586.48 0 $1,586.48

S Brian 560 200.76 760.76 317.58 41.9 $359.48

S Patrick 560 206.66 766.66 0 $0.00

S Bryan 46.69 9.26 55.95 0 $0.00

S Ardian 520 187.04 707.04 332.93 44.04 $376.97

S Sean 520 167.41 687.41 0 $0.00

S Yvon 560 195.55 755.55 587.6 76.04 $663.64

S Steven 718.7 718.7 1866.97 0 $1,866.97

T Jeff 266.26 71.19 337.45 0 $0.00

T Jennifer 98.81 36.21 135.02 0 $0.00

T Robert 560 179.08 739.08 1170.62 141.82 $1,312.44

T Garfield 380.6 122.39 502.99 0 $0.00

V Gregory 560 218.19 778.19 509.48 71.42 $580.90

V William 753.58 753.58 1622.25 0 $1,622.25

V Ashley 560 141.95 701.95 700 70.78 $770.78

W Jared 559.75 168.66 728.41 250.99 29.06 $280.05

W Timothy 556.93 166.33 723.26 834.18 95.92 $930.10

W William 745.28 745.28 1549.88 0 $1,549.88

W La Shia 557.2 213.51 770.71 274.04 37.96 $312.00

W iDavid 560 228.31 788.31 0 $0.00

W Edward 556.36 191.93 748.29 679.96 87.2 $767.16

W Sevren 528.98 175.41 704.39 336.18 41.86 $378.04

W Andrew 739.9 739.9 316.88 0 $316.88

W Brian 200 73.95 273.95 0 $0.00

Z John 560 234.17 794.17 0 $0.00

S Harold 558.52 129.8 688.32 0 $0.00

A Chasity 694.7 694.7 2062.5 0 $2,062.50

K Deborah 560 186.28 746.28 0 $0.00

H Willie 555.88 305.54 861.42 0 $0.00

M James 520 144.63 664.63 0 $0.00

D Jonathan 520 194.35 714.35 0 $0.00

S Sean 557.8 197.99 755.79 0 $0.00

K eJames 560 138.08 698.08 0 $0.00

R Robbin 560 102.72 662.72 0 $0.00

E Debra 560 181.26 741.26 302.3 36.96 $339.26

H Mariana 560 133.41 693.41 0 $0.00

E Eduardo 560 176.54 736.54 0 $0.00

R Dawn 560 181.7 741.7 0 $0.00

F Melissa 560 109.59 669.59 0 $0.00

M Gregory 410.62 109.43 520.05 0 $0.00

B Tucker 560 131.04 691.04 0 $0.00

S Arturo 551.34 174.26 725.6 0 $0.00

H Danielle 560 209.96 769.96 228.31 31.13 $259.44

M Courtney 35.38 35.38 0 $0.00

B Nathaniel 277.31 57.75 335.06 0 $0.00

C James 560 175.59 735.59 0 $0.00

C Diovanni 98.22 19.81 118.03 0 $0.00

C Hollis 560 78.18 638.18 0 $0.00

M Travis 440 41.99 481.99 0 $0.00

S rSandra 30.83 30.83 0 $0.00

S Edward 307.9 307.9 325 0 $325.00

H Livingston 320 320 0 $0.00

F Joe Robert 160 89.61 249.61 0 $0.00

K Thomas 120 120 0 $0.00

H ChowJose 48.18 48.18 0 $0.00

B Wyatt 80 80 0 $0.00

M Brandon 29.96 29.96 0 $0.00

H David 1250 $1,250.00

j william 2595.91 $2,595.91

N Cheryl 4331.96 $4,331.96

S anthony 2403.77 $2,403.77

s christopher 2112.02 $2,112.02

C rBrett 2057.87 $2,057.87

Totals 75570.63 16862.67 106066.05 3789.79 $109,855.84

Case 20-14792-EPK Doc 10 Filed 04/30/20 Page 24 of 24