IN THE UNITED STATES BANKRUPTCY COURT

NORTHERN DISTRICT OF TEXAS

DALLAS DIVISION

IN RE:

One More Recovery, LLC

83-3966180

6842 Michael Talty Ave.

Terrell, TX 75160

Debtor.

Case No.: 24-30808

Chapter: 11

DEBTOR’S AMENDED PLAN OF REORGANIZATION

[DATED JUNE 21, 2024]

Pursuant to section 1121(a) of the Bankruptcy Code, One More Recovery, LLC, the debtor and 

debtor-in-possession in this Case1 hereby proposes this Plan of Reorganization

INTRODUCTION

The purpose of this Plan is to provide the details of the Debtor’s proposed reorganization and 

proposed distributions of money and/or property to their Creditors After the Plan has been 

confirmed, the Bankruptcy Court will retain jurisdiction to determine the allowance of all Claims

and to effectuate and enforce the terms of this Plan.

BACKGROUND

Business History and Operations

Debtor is a Texas entity, established March 13, 2019, which currently operates from Terrell, 

Texas. Debtor operates a towing and vehicle repossession business. 

CONDITIONS TO CONFIRMATION

The Court must find that all creditors and equity interest holders who do not accept the Plan will 

receive at least as much under the Plan as such claim and equity interest holders would receive 

in a chapter 7 liquidation. A liquidation analysis is attached to this Plan as Exhibit “A”.

The Court must find that confirmation of the Plan is not likely to be followed by the liquidation, 

or the need for further financial reorganization, of the Debtor or any successor to the Debtor, 

unless such liquidation or reorganization is proposed in the Plan. The Debtor must also show 

that it will have enough cash over the life of the Plan to make the required Plan payments. 

Attached as Exhibit “B” are projections of Debtor’s revenue and expenses. 

1 Capitalized terms used herein shall have the meaning ascribed them in Article VIII of this Plan.

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Document Page 1 of 52
Debtor’s Amended Plan of Reorganization [Dated June 21, 2024] Page 2

ARTICLE 1: PLAN SUMMARY

1.1. Reorganization: The Plan provides for a reorganization and restructuring of the Debtor’s

financial obligations. 

1.2. Distribution: The Plan provides for a distribution to Creditors in accordance with the 

terms of the Plan from the Debtor over the course of five (5) years from the Debtor’s continued 

business operations.

1.3. Classes: The Plan provides for:

1 Class of priority Claims;

18 Classes of secured Claims;

1 Class of unsecured Claims; and

1 Class of equity security holders.

Unsecured Creditors holding Allowed Claims will receive distributions paid quarterly over five (5) 

years in the following approximate amounts:

DEBTOR PROJECTED QUARTERLY DISTRIBUTION

One More Recovery, LLC $3,000.00 for Quarters 1-6

$25,500.00 for Quarters 7-20

This Plan also provides for the payment of administrative and priority claims.

All creditors and equity security holders should refer to Articles 3 through 4 of this Plan for 

information regarding the precise treatment of their claim. Your rights may be affected. You 

should read these papers carefully and discuss them with your attorney, if you have one. (If 

you do not have an attorney, you may wish to consult one.)

ARTICLE 2: CLASSIFICATION OF CLAIMS AND INTERESTS

2.1. Class 1A .................. The claim of Ad Valorem Tax Authorities to the extent Allowed as 

Secured Claims under 11 U.S.C. § 506 of the Bankruptcy Code.

2.2. Class 1B .................. The Ally 5710 Claim to the extent Allowed as a Secured Claim 

under 11 U.S.C. § 506 of the Bankruptcy Code.

2.3. Class 1C .................. The Ally 5790 Claim to the extent Allowed as a Secured Claim 

under 11 U.S.C. § 506 of the Bankruptcy Code.

2.4. Class 1D .................. The Ally 4928 Claim to the extent Allowed as a Secured Claim 

under 11 U.S.C. § 506 of the Bankruptcy Code.

2.5. Class 1E .................. The First Citizens 0727 Claim to the extent Allowed as a Secured 

Claim under 11 U.S.C. § 506 of the Bankruptcy Code.

2.6. Class 1F .................. The First Citizens 1846 Claim to the extent Allowed as a Secured 

Claim under 11 U.S.C. § 506 of the Bankruptcy Code.

2.7. Class 1G .................. The First Citizens 0525 Claim to the extent Allowed as a Secured 

Claim under 11 U.S.C. § 506 of the Bankruptcy Code.

2.8. Class 1H .................. The Beacon Claim to the extent Allowed as a Secured Claim under 

11 U.S.C. § 506 of the Bankruptcy Code.

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Document Page 2 of 52
Debtor’s Amended Plan of Reorganization [Dated June 21, 2024] Page 3

2.9. Class 1I .................. The Hatzendorf Claim to the extent Allowed as a Secured Claim 

under 11 U.S.C. § 506 of the Bankruptcy Code.

2.10. Class 1J .................. The Fora Claim to the extent Allowed as a Secured Claim under 

11 U.S.C. § 506 of the Bankruptcy Code.

2.11. Class 1K .................. The Springer Claim to the extent Allowed as a Secured Claim 

under 11 U.S.C. § 506 of the Bankruptcy Code.

2.12. Class 1L .................. The Pawnee Claim to the extent Allowed as a Secured Claim 

under 11 U.S.C. § 506 of the Bankruptcy Code.

2.13. Class 1M .................. The Regions Claim to the extent Allowed as a Secured Claim 

under 11 U.S.C. § 506 of the Bankruptcy Code.

2.14. Class 1N .................. The Santander Claim to the extent Allowed as a Secured Claim 

under 11 U.S.C. § 506 of the Bankruptcy Code.

2.15. Class 1O .................. The American Claim to the extent Allowed as a Secured Claim 

under 11 U.S.C. § 506 of the Bankruptcy Code.

2.16. Class 1P .................. The Velocity Claim to the extent Allowed as a Secured Claim 

under 11 U.S.C. § 506 of the Bankruptcy Code.

2.17. Class 1Q .................. The Wells Fargo Claim to the extent Allowed as a Secured Claim 

under 11 U.S.C. § 506 of the Bankruptcy Code.

2.18. Class 1R .................. The Quest Claim to the extent Allowed as a Secured Claim under 

11 U.S.C. § 506 of the Bankruptcy Code.

2.19. Class 2 .................. All Allowed Claims entitled to priority under § 507(a) of the 

Bankruptcy Code (except administrative expense claims under § 

507(a)(2) and priority tax claims under § 507(a)(8)).

2.20. Class 3 .................. All non-priority unsecured Claims Allowed under § 502 of the 

Bankruptcy Code.

2.21. Class 4 .................. Equity Interests of the Debtor

ARTICLE 3: TREATMENT OF ADMINISTRATIVE EXPENSE CLAIMS, PRIOIRTY TAX CLAIMS AND 

QUARTERLY AND COURT FEES

3.1. Unclassified Claims Under section § 1123(a)(1), administrative expense claims, and 

priority tax claims are not in classes.

3.2. Administrative 

Expense Claims

Each holder of an administrative expense claim allowed under § 

503 of the Code, will be paid in full on the effective date of this 

Plan by the Debtor, but only to the extent of each such Debtor’s 

liability, in cash, or upon such other terms as may be agreed upon 

by the holder of the claim and the Debtor as set forth in the 

following sections 3.3 through and including 3.4 or postconfirmation. NOTE: This treatment is materially altered in the 

event of confirmation pursuant to § 1191(b) as to claims arising 

under §§ 507(a)(2) and (3) as noted in section 3.6 of this Plan.

3.3. Priority Tax Claims Each holder of an Allowed Priority Tax Claim against the Debtor 

shall receive on the Effective Date, in full satisfaction, release and 

discharge of such Allowed Priority Tax Claim, at the election of 

the liable Debtor, either: (i) Cash payment in the amount of such 

holder’s Allowed Priority Tax Claim; (ii) deferred Cash payments 

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Document Page 3 of 52
Debtor’s Amended Plan of Reorganization [Dated June 21, 2024] Page 4

over a period not to exceed five (5) years, from the Petition Date 

of a value as of the Effective Date, equal to the Allowed amount 

of such Claim; or (iii) such other terms as may be agreed upon by 

such holder and the liable Debtor. The rate of interest to be paid 

on Allowed Priority Tax Claims that are paid out over five (5) 

years shall be equal to the underpayment rate specified in 26 

U.S.C. § 6621 (determined without regard to 26 U.S.C. § 6621(a)) 

as of the Effective Date (the underpayment rate is currently 

8.0%).

IRS Priority Tax Claim. Estimated at $775.53 based upon the 

proof of claim filed by the IRS. Which Claim, if allowed and paid 

interest over a period of 6 months would result in a monthly 

payment of $133.00.

Address for Payment. Until further notice, all payments due the 

Comptroller shall be sent to the following address: Internal 

Revenue Service, 1100 Commerce St, M/S 5026 DAL, Dallas, TX, 

75242.

COMPTROLLER OF PUBLIC ACCOUNTS AND TWC

Notwithstanding anything else to the contrary in the Plan or 

Confirmation Order, these provisions will govern the treatment 

of the claims of the Comptroller of Public Accounts (the 

“Comptroller”) and the Texas Workforce Commission (the 

“TWC”): (1) nothing provided in the Plan or Confirmation Order 

shall affect or impair any statutory or common law setoff rights 

of the Comptroller or the TWC in accordance with 11 U.S.C. § 

553; (2) nothing provided in the Plan or Confirmation Order shall 

affect or impair any rights of the Comptroller or the TWC to 

pursue any non-debtor third parties for tax debts or claims, and 

the Comptroller and TWC specifically opt out of any third party 

releases, if any; (3) nothing provided in the Plan or Confirmation 

Order shall be construed to preclude the payment of interest on 

the Comptroller's or the TWC’s administrative expense tax 

claims; (4) to the extent that interest is payable with respect to 

any administrative expense, priority or secured tax claim of the 

Comptroller or the TWC, the interest rate shall be the statutory 

interest rate, currently 9.5% per annum; and (5) nothing 

provided in the Plan or Confirmation Order impacts the 

governmental claims bar date, and Comptroller and TWC may 

amend their claims at any point. 

The Comptroller and TWC shall not be required to file any proof 

of claim, motion, or request for payment to be paid for any 

administrative claims. The Comptroller and TWC shall not be 

required to file any proof of claim, motion, or request for 

payment to be paid for any obligations that arise or have arisen 

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Document Page 4 of 52
Debtor’s Amended Plan of Reorganization [Dated June 21, 2024] Page 5

in the ordinary course of the Debtors’ business, including all postpetition taxes incurred by the Debtors and/or Reorganized 

Debtors after the Petition Date. All post-petition taxes owed to 

the Comptroller and TWC shall be paid in full with applicable 

interest on or before the Effective Date, or as otherwise agreed 

by the Comptroller and/or TWC, whichever is the respective 

agency for such post-petition taxes. If any post-petition taxes or 

Administrative Claims owed to the Comptroller or TWC are not 

due on the Effective Date, then such post-petition taxes or 

Administrative Claim shall be paid in the ordinary course of 

business in accordance with applicable law.

All priority tax claims owed to the Texas Comptroller and/or the 

TWC shall be paid in full either (1) on the Effective Date; (2) in 

equal monthly installments of principal and interest no later than 

sixty (60) months of the Debtors’ bankruptcy petition date, with 

the first payment due on the Effective Date and every month 

thereafter on that same day of the month; or (3) as otherwise 

agreed to by the Comptroller and/or the TWC. The Comptroller’s 

and the TWC’s priority tax claims shall accrue interest at the 

statutory rate of interest, currently 9.5% per annum until paid in 

full.

A failure by the Debtors or Reorganized Debtors to make a plan 

payment to an agency of the State of Texas shall be an Event of 

Default. If the Debtors or Reorganized Debtors fail to cure an 

Event of Default as to an agency of the State of Texas within five

(5) days after service of a written notice of default by email to 

counsel for Debtors at robert@demarcomitchell.com, then that 

agency may (a) enforce the entire amount of its claim; (b) 

exercise any and all rights and remedies available under 

applicable non-bankruptcy law; and (c) seek such relief as may be 

appropriate in this court. The Debtors and/or Reorganized 

Debtors can receive up to three (3) notices of default, however, 

the third default cannot be cured. The Texas Comptroller and 

TWC preserve all available bankruptcy and state law remedies, if 

any, in the event of default of payment on claims as laid out 

herein above.

Debtors and/or Reorganized Debtors shall file all delinquent 

returns due and owing to Texas Comptroller or TWC on or before 

Effective date and stay current on filings thereafter. 

Notwithstanding anything to the contrary in the Plan or this 

Order, the Debtors and/or Reorganized Debtors will retain 

documents for the four-year inspection period set forth in Texas 

Tax Code § 111.0041(a) (or for any pending audits, the later of 

four years or the time any and all claim(s) based on such audit 

are resolved).

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Document Page 5 of 52
Debtor’s Amended Plan of Reorganization [Dated June 21, 2024] Page 6

Comptroller Priority Tax Claim. Estimated at $1,049.70 based 

upon the proof of claim filed by the Comptroller. Which Claim, if 

allowed and paid interest over a period of 6 months would result 

in a monthly payment of $180.00.

Address for Payment. Until further notice, all payments due the 

Comptroller shall be sent to the following address: Revenue 

Accounting Division, Attention: Bankruptcy, P.O. Box 13528, 

Austin, TX, 78711.

3.4. EXCEPTION: 

Payment of 

Administrative 

Expense Claims 

Through Plan Term

If the Plan is confirmed pursuant to § 1191(b) any and all claims 

of a kind specified in paragraph (2) or (3) of § 507(a) of the 

Bankruptcy Code shall be paid the Allowed amount of such claim 

in equal monthly installments during the Plan Term commencing 

on the Effective Date or upon such other terms as may be agreed 

upon by the holder of the claim and the Debtor.

ARTICLE 4: TREATMENT OF CLAIMS AND INTERESTS UNDER THE PLAN

4.1.Claims and Interests shall be treated as follows under this Plan

Class Impairment Treatment

Class 1A - Secured 

Claim of Ad Valorem

Tax Authorities

R Impaired

£ Unimpaired

Each holder of an Allowed Class 1A Claim 

payable to a taxing authority for ad valorem

taxes shall retain its full rights and liens to the 

extent of its Allowed Secured Tax Claim until its 

Allowed Secured Tax Claim has been paid in full.

Payment shall be made in full no later than five

(5) years from and after the Petition Date in 

equal monthly payments. More specifically, 

the prepetition and post-petition ad valorem

taxes of the holder of an Allowed Class 1A Claim 

shall be treated as follows:

Liens and Interest. Any and all liens (both those 

arising prepetition and post-petition) held by 

the holder of an Allowed Class 1A Claim shall be 

preserved in any transfer of assets under the 

Plan. Each holder of an Allowed Class 1A Claim 

shall be entitled to receive interest from the 

Petition Date to the Effective Date pursuant to 

11 U.S.C. § 506(b), as well as from the Effective 

Date until paid in full at a statutory rate of 1% 

per month as required by 11 U.S.C. § 511. If the 

post-petition ad valorem taxes are not paid 

prior to the State law delinquency date, each 

holder of an Allowed Class 1A Claim shall be 

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Document Page 6 of 52
Debtor’s Amended Plan of Reorganization [Dated June 21, 2024] Page 7

entitled to receive any penalties and interest 

that accrue under State law based on the 

nonpayment of such tax.

Default. In the event the Reorganized Debtor 

fails to timely pay an Allowed Class 1A Claim or 

a post-petition tax in compliance with the Plan, 

the Reorganized Debtor shall be in default, and, 

subject to Section 10.4 of the Plan, the holder 

of the affected Allowed Class 1A Claim may 

pursue remedies in accordance with that 

section against the Reorganized Debtor.

Estimation of Amount. Debtor estimates the 

aggregate of all Allowed Class 1A Claims is 

$12,668.53 based upon the Court’s claim 

register. The Claim(s), if allowed and paid 

interest would result in monthly payments of:

Forny ISD paid over 4.5 years: $204.00

Kaufman County paid over 1 year: $239.00

McLennan County paid over 1 year: $134.00

Class 1B - Secured 

Claim of Ally 5710

£ Impaired

R Unimpaired

Class 1B Summary. Class 1B consists of the 

Secured Claim of Ally 5710. Ally 5710 has filed 

a proof of claim asserting it is owed 

approximately $35,790.81. The Allowed Class 

1B Claim shall be modified as set forth herein 

and paid by Reorganized Debtor as follows.

Principal Amount. The unpaid principal balance 

of the Allowed Class 1B Claim is hereby allowed 

as an Allowed Secured Claim in the amount of 

$35,790.81.

Interest. Simple interest shall accrue on the 

unpaid balance owed to the Allowed Class 1B

Claim holder at the rate of 8.44% from and after 

the Confirmation Date.

Payments. The Allowed Class 1B Claim, plus 

interest thereon, shall be paid by Reorganized 

Debtor in consecutive monthly installments of 

$733.00 commencing the first (1st) day of the 

first full calendar month following the Effective 

Date, and continuing on the same day each 

month thereafter until the Allowed Class 1B

Claim is paid in full.

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Document Page 7 of 52
Debtor’s Amended Plan of Reorganization [Dated June 21, 2024] Page 8

Maturity. The maturity date shall be the first 

(1st) day of the 60th month after the first full 

calendar month following the Effective Date, at 

which time the remaining balance due and 

owing, if any, shall be paid in full.

Pre-Payment. At any time after the Effective 

Date, without penalty or premium, the Allowed 

Class 1B Claim may be prepaid, in whole or in 

part, in the sole discretion of Reorganized 

Debtor.

Collateral. Except to the extent inconsistent 

herewith or with the law, the validity and 

priority of the lien and security interest securing 

the Allowed Class 1B Claim shall remain in full 

force and effect following the Effective Date. 

Default. In the event Reorganized Debtor fails 

to timely pay an Allowed Class 1B Claim 

Reorganized Debtor shall be in default, and, 

subject to Section 10.4 of the Plan, the holder 

of the affected Allowed Class 1B Claim may 

pursue remedies in accordance with that 

section.

Address for Payment. Until further notice, all 

payments due the holder of an Allowed Class 1B

Claim shall be sent to the following address: 

AIS Portfolio Services, LLC, 4515 N Santa Fe 

Ave., Dept. APS, Oklahoma City, OK 73118.

Class 1C - Secured 

Claim of Ally 5790

R Impaired

£ Unimpaired

Class 1C Summary. Class 1C consists of the 

Secured Claim of Ally 5790. Ally 5790 has filed 

a proof of claim asserting it is owed 

approximately $60,199.75. The Allowed Class 

1C Claim shall be modified as set forth herein 

and paid by Reorganized Debtor as follows.

Principal Amount. The unpaid principal balance 

of the Allowed Class 1C Claim is hereby allowed 

as an Allowed Secured Claim in the amount of 

$49,725.00.

Interest. Simple interest shall accrue on the 

unpaid balance owed to the Allowed Class 1D

Claim holder at the rate of 8.5% from and after 

the Confirmation Date.

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Document Page 8 of 52
Debtor’s Amended Plan of Reorganization [Dated June 21, 2024] Page 9

Payments. The Allowed Class 1C Claim, plus 

interest thereon, shall be paid by Reorganized 

Debtor in consecutive monthly installments of 

$1,020.00 commencing the first (1st) day of the 

first full calendar month following the Effective 

Date, and continuing on the same day each 

month thereafter until the Allowed Class 1C

Claim is paid in full.

Maturity. The maturity date shall be the first 

(1st) day of the 60th month after the first full 

calendar month following the Effective Date, at 

which time the remaining balance due and 

owing, if any, shall be paid in full.

Pre-Payment. At any time after the Effective 

Date, without penalty or premium, the Allowed 

Class 1C Claim may be prepaid, in whole or in 

part, in the sole discretion of Reorganized 

Debtor.

Collateral. Except to the extent inconsistent 

herewith or with the law, the validity and 

priority of the lien and security interest securing 

the Allowed Class 1C Claim shall remain in full 

force and effect following the Effective Date. 

Default. In the event Reorganized Debtor fails 

to timely pay an Allowed Class 1C Claim 

Reorganized Debtor shall be in default, and, 

subject to Section 10.4 of the Plan, the holder 

of the affected Allowed Class 1C Claim may 

pursue remedies in accordance with that 

section.

Address for Payment. Until further notice, all 

payments due the holder of an Allowed Class 1C

Claim shall be sent to the following address: 

Payment Processing Center, P.O. Box 78367, 

Phoenix, AZ 85062.

Class 1D - Secured 

Claim of Ally 4928

R Impaired

£ Unimpaired

Class 1D Summary. Class 1D consists of the 

Secured Claim of Ally 4928. Ally 4928 has filed 

a proof of claim asserting it is owed 

approximately $35,512.77. The Allowed Class 

1D Claim shall be modified as set forth herein 

and paid by Reorganized Debtor as follows.

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Document Page 9 of 52
Debtor’s Amended Plan of Reorganization [Dated June 21, 2024] Page 10

Principal Amount. The unpaid principal balance 

of the Allowed Class 1D Claim is hereby allowed 

as an Allowed Secured Claim in the amount of 

$35,512.77.

Interest. Simple interest shall accrue on the 

unpaid balance owed to the Allowed Class 1D

Claim holder at the rate of 8.5% from and after 

the Confirmation Date.

Payments. The Allowed Class 1D Claim, plus 

interest thereon, shall be paid by Reorganized 

Debtor in consecutive monthly installments of 

$728.00 commencing the first (1st) day of the 

first full calendar month following the Effective 

Date, and continuing on the same day each 

month thereafter until the Allowed Class 1D

Claim is paid in full.

Maturity. The maturity date shall be the first 

(1st) day of the 60th month after the first full 

calendar month following the Effective Date, at 

which time the remaining balance due and 

owing, if any, shall be paid in full.

Pre-Payment. At any time after the Effective 

Date, without penalty or premium, the Allowed 

Class 1D Claim may be prepaid, in whole or in 

part, in the sole discretion of Reorganized 

Debtor.

Collateral. Except to the extent inconsistent 

herewith or with the law, the validity and 

priority of the lien and security interest securing 

the Allowed Class 1D Claim shall remain in full 

force and effect following the Effective Date. 

Default. In the event Reorganized Debtor fails 

to timely pay an Allowed Class 1D Claim 

Reorganized Debtor shall be in default, and, 

subject to Section 10.4 of the Plan, the holder 

of the affected Allowed Class 1D Claim may 

pursue remedies in accordance with that 

section.

Address for Payment. Until further notice, all 

payments due the holder of an Allowed Class 1B

Claim shall be sent to the following address: 

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Document Page 10 of 52
Debtor’s Amended Plan of Reorganization [Dated June 21, 2024] Page 11

AIS Portfolio Services, LLC, 4515 N Santa Fe 

Ave., Dept. APS, Oklahoma City, OK 73118.

Class 1E - Secured 

Claim of First Citizens 

0727

R Impaired

£ Unimpaired

Class 1E Summary. Class 1E consists of the 

Secured Claim of First Citizens 0727. First 

Citizens 0727 has filed a proof of claim asserting 

it is owed approximately $71,324.34. The 

Allowed Class 1E Claim shall be modified as set 

forth herein and paid by Reorganized Debtor as 

follows.

Principal Amount. The unpaid principal balance 

of the Allowed Class 1E Claim is hereby allowed 

as an Allowed Secured Claim in the amount of 

$71,324.34.

Interest. Simple interest shall accrue on the 

unpaid balance owed to the Allowed Class 1E

Claim holder at the rate of .025% from and after 

the Confirmation Date.

Payments. The Allowed Class 1E Claim, plus 

interest thereon, shall be paid by Reorganized 

Debtor in consecutive monthly installments of 

$1,189.00 commencing the first (1st) day of the 

first full calendar month following the Effective 

Date, and continuing on the same day each 

month thereafter until the Allowed Class 1E

Claim is paid in full.

Maturity. The maturity date shall be the first 

(1st) day of the 60th month after the first full 

calendar month following the Effective Date, at 

which time the remaining balance due and 

owing, if any, shall be paid in full.

Pre-Payment. At any time after the Effective 

Date, without penalty or premium, the Allowed 

Class 1E Claim may be prepaid, in whole or in 

part, in the sole discretion of Reorganized 

Debtor.

Collateral. Except to the extent inconsistent 

herewith or with the law, the validity and 

priority of the lien and security interest securing 

the Allowed Class 1E Claim shall remain in full 

force and effect following the Effective Date. 

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Document Page 11 of 52
Debtor’s Amended Plan of Reorganization [Dated June 21, 2024] Page 12

Default. In the event Reorganized Debtor fails 

to timely pay an Allowed Class 1E Claim 

Reorganized Debtor shall be in default, and, 

subject to Section 10.4 of the Plan, the holder 

of the affected Allowed Class 1E Claim may 

pursue remedies in accordance with that 

section.

Address for Payment. Until further notice, all 

payments due the holder of an Allowed Class 1C

Claim shall be sent to the following address: 

First Citizens Bank & Trust, Attention Recovery, 

10201 Centurion PKWY N, Jacksonville, FL 

32256.

Class 1F - Secured 

Claim of First Citizens 

1946

R Impaired

£ Unimpaired 

Class 1F Summary. Class 1F consists of the 

Secured Claim of First Citizens 1946. First 

Citizens 1946 has filed a proof of claim asserting 

it is owed approximately $120,413.59. The 

Allowed Class 1F Claim shall be modified as set 

forth herein and paid by Reorganized Debtor as 

follows.

Principal Amount. The unpaid principal balance 

of the Allowed Class 1F Claim is hereby allowed 

as an Allowed Secured Claim in the amount of 

$120,413.59.

Interest. Simple interest shall accrue on the 

unpaid balance owed to the Allowed Class 1F

Claim holder at the rate of .025% from and after 

the Confirmation Date.

Payments. The Allowed Class 1F Claim, plus 

interest thereon, shall be paid by Reorganized 

Debtor in consecutive monthly installments of 

$2,007.00 commencing the first (1st) day of the 

first full calendar month following the Effective 

Date, and continuing on the same day each 

month thereafter until the Allowed Class 1F

Claim is paid in full.

Maturity. The maturity date shall be the first 

(1st) day of the 60th month after the first full 

calendar month following the Effective Date, at 

which time the remaining balance due and 

owing, if any, shall be paid in full.

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Document Page 12 of 52
Debtor’s Amended Plan of Reorganization [Dated June 21, 2024] Page 13

Pre-Payment. At any time after the Effective 

Date, without penalty or premium, the Allowed 

Class 1F Claim may be prepaid, in whole or in 

part, in the sole discretion of Reorganized 

Debtor.

Collateral. Except to the extent inconsistent 

herewith or with the law, the validity and 

priority of the lien and security interest securing 

the Allowed Class 1F Claim shall remain in full 

force and effect following the Effective Date. 

Default. In the event Reorganized Debtor fails 

to timely pay an Allowed Class 1F Claim 

Reorganized Debtor shall be in default, and, 

subject to Section 10.4 of the Plan, the holder 

of the affected Allowed Class 1F Claim may 

pursue remedies in accordance with that 

section.

Address for Payment. Until further notice, all 

payments due the holder of an Allowed Class 1C

Claim shall be sent to the following address: 

First Citizens Bank & Trust, Attention Recovery, 

10201 Centurion PKWY N, Jacksonville, FL 

32256.

Class 1G - Secured 

Claim of First Citizens 

0525

R Impaired

£ Unimpaired 

Class 1G Summary. Class 1G consists of the 

Secured Claim of First Citizens 0525. First 

Citizens 0525 has filed a proof of claim asserting 

it is owed approximately $138,477.12. The 

Allowed Class 1G Claim shall be modified as set 

forth herein and paid by Reorganized Debtor as 

follows.

Principal Amount. The unpaid principal balance 

of the Allowed Class 1G Claim is hereby allowed 

as an Allowed Secured Claim in the amount of 

$138,477.12.

Interest. Simple interest shall accrue on the 

unpaid balance owed to the Allowed Class 1G

Claim holder at the rate of .025% from and after 

the Confirmation Date.

Payments. The Allowed Class 1G Claim, plus 

interest thereon, shall be paid by Reorganized 

Debtor in consecutive monthly installments of 

$2,308.00 commencing the first (1st) day of the 

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Document Page 13 of 52
Debtor’s Amended Plan of Reorganization [Dated June 21, 2024] Page 14

first full calendar month following the Effective 

Date, and continuing on the same day each 

month thereafter until the Allowed Class 1G

Claim is paid in full.

Maturity. The maturity date shall be the first 

(1st) day of the 60th month after the first full 

calendar month following the Effective Date, at 

which time the remaining balance due and 

owing, if any, shall be paid in full.

Pre-Payment. At any time after the Effective 

Date, without penalty or premium, the Allowed 

Class 1G Claim may be prepaid, in whole or in 

part, in the sole discretion of Reorganized 

Debtor.

Collateral. Except to the extent inconsistent 

herewith or with the law, the validity and 

priority of the lien and security interest securing 

the Allowed Class 1G Claim shall remain in full 

force and effect following the Effective Date. 

Default. In the event Reorganized Debtor fails 

to timely pay an Allowed Class 1G Claim 

Reorganized Debtor shall be in default, and, 

subject to Section 10.4 of the Plan, the holder 

of the affected Allowed Class 1G Claim may 

pursue remedies in accordance with that 

section.

Address for Payment. Until further notice, all 

payments due the holder of an Allowed Class 1C

Claim shall be sent to the following address: 

First Citizens Bank & Trust, Attention Recovery, 

10201 Centurion PKWY N, Jacksonville, FL 

32256.

Class 1H - Secured 

Claim of Beacon

R Impaired

£ Unimpaired 

Class 1H Summary. Class 1H consists of the 

Secured Claim of Beacon. Beacon has not filed 

a proof of claim. Debtor asserts Amur is owed 

approximately $161,197.06. The Allowed Class 

1H Claim shall be modified as set forth herein 

and paid by Reorganized Debtor as follows.

Principal Amount. The unpaid principal balance 

of the Allowed Class 1H Claim is hereby allowed 

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Document Page 14 of 52
Debtor’s Amended Plan of Reorganization [Dated June 21, 2024] Page 15

as an Allowed Secured Claim in the amount of 

$161,197.06.

Interest. Simple interest shall accrue on the 

unpaid balance owed to the Allowed Class 1H

Claim holder at the rate of 9% from and after 

the Confirmation Date.

Payments. The Allowed Class 1H Claim, plus 

interest thereon, shall be paid by Reorganized 

Debtor in consecutive monthly installments of 

$2,687.00 commencing the first (1st) day of the 

first full calendar month following the Effective 

Date, and continuing on the same day each 

month thereafter until the Allowed Class 1H

Claim is paid in full.

Maturity. The maturity date shall be the first 

(1st) day of the 60th month after the first full 

calendar month following the Effective Date, at 

which time the remaining balance due and 

owing, if any, shall be paid in full.

Pre-Payment. At any time after the Effective 

Date, without penalty or premium, the Allowed 

Class 1H Claim may be prepaid, in whole or in 

part, in the sole discretion of Reorganized 

Debtor.

Collateral. Except to the extent inconsistent 

herewith or with the law, the validity and 

priority of the lien and security interest securing 

the Allowed Class 1H Claim shall remain in full 

force and effect following the Effective Date. 

Default. In the event Reorganized Debtor fails 

to timely pay an Allowed Class 1H Claim 

Reorganized Debtor shall be in default, and, 

subject to Section 10.4 of the Plan, the holder 

of the affected Allowed Class 1H Claim may 

pursue remedies in accordance with that 

section.

Address for Payment. Until further notice, all 

payments due the holder of an Allowed Class 1C

Claim shall be sent to the following address: 

Beacon Funding Corporation, 3400 Dundee 

Road, Suite 180 Northbrook, IL 60062.

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Document Page 15 of 52
Debtor’s Amended Plan of Reorganization [Dated June 21, 2024] Page 16

Class 1I - Secured Claim 

of Hartzendorf

R Impaired

£ Unimpaired 

Class 1I Summary. Class 1I consists of the 

Secured Claim of Hartzendorf. Hartzendorf has 

filed a proof of claim asserting it is owed 

approximately $438,236.07. The Allowed Class 

1G Claim shall be modified as set forth herein 

and paid by Reorganized Debtor as follows.

Principal Amount. The unpaid principal balance 

of the Allowed Class 1I Claim is hereby allowed 

as an Allowed Secured Claim in the amount of 

$438,236.07.

Interest. Simple interest shall accrue on the 

unpaid balance owed to the Allowed Class 1I

Claim holder at the rate of 9.00% from and after 

the Confirmation Date.

Payments. The Allowed Class 1I Claim, plus 

interest thereon, shall be paid by Reorganized 

Debtor in consecutive monthly installments of 

$4,445.00 commencing the first (1st) day of the 

first full calendar month following the Effective 

Date, and continuing on the same day each 

month thereafter until the Allowed Class 1I

Claim is paid in full.

Maturity. The maturity date shall be the first 

(1st) day of the 180th month after the first full 

calendar month following the Effective Date, at 

which time the remaining balance due and 

owing, if any, shall be paid in full.

Pre-Payment. At any time after the Effective 

Date, without penalty or premium, the Allowed 

Class 1I Claim may be prepaid, in whole or in 

part, in the sole discretion of Reorganized 

Debtor.

Collateral. Except to the extent inconsistent 

herewith or with the law, the validity and 

priority of the lien and security interest securing 

the Allowed Class 1I Claim shall remain in full 

force and effect following the Effective Date. 

Default. In the event Reorganized Debtor fails 

to timely pay an Allowed Class 1I Claim 

Reorganized Debtor shall be in default, and, 

subject to Section 10.4 of the Plan, the holder 

of the affected Allowed Class 1I Claim may 

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Document Page 16 of 52
Debtor’s Amended Plan of Reorganization [Dated June 21, 2024] Page 17

pursue remedies in accordance with that 

section.

Address for Payment. Until further notice, all 

payments due the holder of an Allowed Class 1C

Claim shall be sent to the following address: 

Beverley Hertzendorf, 2618 Dove Creek Lane, 

Carrollton, TX 75006.

Class 1J - Secured 

Claim of Fora

R Impaired

£ Unimpaired 

Class 1J Summary. Class 1J consists of the 

Secured Claim of Fora. Fora has filed two (2)

proofs of claim asserting it is owed 

approximately $116,740.40. The Allowed Class 

1G Claim shall be modified as set forth herein 

and paid by Reorganized Debtor as follows.

Principal Amount. The unpaid principal balance 

of the Allowed Class 1J Claim is hereby allowed 

as an Allowed Secured Claim in the amount of 

$0.00 as there are no assets to secure the 

obligation. The Class 1J Claim shall be treated 

as a Class 3 Claim holder to the extent its Claim 

is Allowed.

Class 1K - Secured 

Claim of Springer

R Impaired

£ Unimpaired 

Class 1K Summary. Class 1K consists of the 

Secured Claim of Springer. Springer has filed a 

proof of claim asserting it is owed 

approximately $139,928.75. The Allowed Class 

1G Claim shall be modified as set forth herein 

and paid by Reorganized Debtor as follows.

Principal Amount. The unpaid principal balance 

of the Allowed Class 1K Claim is hereby allowed 

as an Allowed Secured Claim in the amount of 

$139,928.75.

Interest. Simple interest shall accrue on the 

unpaid balance owed to the Allowed Class 1K

Claim holder at the rate of 11% from and after 

the Confirmation Date.

Payments. The Allowed Class 1K Claim, plus 

interest thereon, shall be paid by Reorganized 

Debtor in consecutive monthly installments of 

$1,444.00 commencing the first (1st) day of the 

first full calendar month following the Effective 

Date, and continuing on the same day each 

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Document Page 17 of 52
Debtor’s Amended Plan of Reorganization [Dated June 21, 2024] Page 18

month thereafter until the Allowed Class 1K

Claim is paid in full.

Maturity. The maturity date shall be the first 

(1st) day of the 240th month after the first full 

calendar month following the Effective Date, at 

which time the remaining balance due and 

owing, if any, shall be paid in full.

Pre-Payment. At any time after the Effective 

Date, without penalty or premium, the Allowed 

Class 1K Claim may be prepaid, in whole or in 

part, in the sole discretion of Reorganized 

Debtor.

Collateral. Except to the extent inconsistent 

herewith or with the law, the validity and 

priority of the lien and security interest securing 

the Allowed Class 1K Claim shall remain in full 

force and effect following the Effective Date. 

Default. In the event Reorganized Debtor fails 

to timely pay an Allowed Class 1K Claim 

Reorganized Debtor shall be in default, and, 

subject to Section 10.4 of the Plan, the holder 

of the affected Allowed Class 1K Claim may 

pursue remedies in accordance with that 

section.

Address for Payment. Until further notice, all 

payments due the holder of an Allowed Class 1C

Claim shall be sent to the following address: 

Mayre Springer Living Trust, c/o TexStar 

Escrow, 5809 Acacia Circle, El Paso, TX 79912.

Class 1L - Secured 

Claim of Pawnee

R Impaired

£ Unimpaired 

Class 1L Summary. Class 1L consists of the 

Secured Claim of Pawnee. Pawnee has filed a 

proof of claim asserting it is owed 

approximately $114,696.55. The Allowed Class 

1G Claim shall be modified as set forth herein 

and paid by Reorganized Debtor as follows.

Principal Amount. The unpaid principal balance 

of the Allowed Class 1L Claim is hereby allowed 

as an Allowed Secured Claim in the amount of 

$114,696.55.

Interest. Simple interest shall accrue on the 

unpaid balance owed to the Allowed Class 1L

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Document Page 18 of 52
Debtor’s Amended Plan of Reorganization [Dated June 21, 2024] Page 19

Claim holder at the rate of 0% from and after 

the Confirmation Date.

Payments. The Allowed Class 1L Claim, plus 

interest thereon, shall be paid by Reorganized 

Debtor in consecutive monthly installments of 

$1,916.00 commencing the first (1st) day of the 

first full calendar month following the Effective 

Date, and continuing on the same day each 

month thereafter until the Allowed Class 1L

Claim is paid in full.

Maturity. The maturity date shall be the first 

(1st) day of the 60th month after the first full 

calendar month following the Effective Date, at 

which time the remaining balance due and 

owing, if any, shall be paid in full.

Pre-Payment. At any time after the Effective 

Date, without penalty or premium, the Allowed 

Class 1L Claim may be prepaid, in whole or in 

part, in the sole discretion of Reorganized 

Debtor.

Collateral. Except to the extent inconsistent 

herewith or with the law, the validity and 

priority of the lien and security interest securing 

the Allowed Class 1L Claim shall remain in full 

force and effect following the Effective Date. 

Default. In the event Reorganized Debtor fails 

to timely pay an Allowed Class 1L Claim 

Reorganized Debtor shall be in default, and, 

subject to Section 10.4 of the Plan, the holder 

of the affected Allowed Class 1L Claim may 

pursue remedies in accordance with that 

section.

Address for Payment. Until further notice, all 

payments due the holder of an Allowed Class 1C

Claim shall be sent to the following address: 

Pawnee Leasing Corporation, 3801 

Automation Way Suite 207, Fort Collins, CO 

80525.

Class 1M - Secured 

Claim of Regions

R Impaired

£ Unimpaired 

Class 1M Summary. Class 1M consists of the 

Secured Claim of Regions. Regions has filed a 

proof of claim asserting it is owed 

approximately $196,181.74. The Allowed Class 

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Document Page 19 of 52
Debtor’s Amended Plan of Reorganization [Dated June 21, 2024] Page 20

1G Claim shall be modified as set forth herein 

and paid by Reorganized Debtor as follows.

Principal Amount. The unpaid principal balance 

of the Allowed Class 1M Claim is hereby 

allowed as an Allowed Secured Claim in the 

amount of $152,785.86.

Interest. Simple interest shall accrue on the 

unpaid balance owed to the Allowed Class 1M

Claim holder at the rate of 8.5% from and after 

the Confirmation Date.

Payments. The Allowed Class 1M Claim, plus 

interest thereon, shall be paid by Reorganized 

Debtor in consecutive monthly installments of 

$3,140.00 commencing the first (1st) day of the 

first full calendar month following the Effective 

Date, and continuing on the same day each 

month thereafter until the Allowed Class 1M

Claim is paid in full.

Maturity. The maturity date shall be the first 

(1st) day of the 60th month after the first full 

calendar month following the Effective Date, at 

which time the remaining balance due and 

owing, if any, shall be paid in full.

Pre-Payment. At any time after the Effective 

Date, without penalty or premium, the Allowed 

Class 1M Claim may be prepaid, in whole or in 

part, in the sole discretion of Reorganized 

Debtor.

Collateral. Except to the extent inconsistent 

herewith or with the law, the validity and 

priority of the lien and security interest securing 

the Allowed Class 1M Claim shall remain in full 

force and effect following the Effective Date. 

Default. In the event Reorganized Debtor fails 

to timely pay an Allowed Class 1M Claim 

Reorganized Debtor shall be in default, and, 

subject to Section 10.4 of the Plan, the holder 

of the affected Allowed Class 1M Claim may 

pursue remedies in accordance with that 

section.

Address for Payment. Until further notice, all 

payments due the holder of an Allowed Class 1C

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Document Page 20 of 52
Debtor’s Amended Plan of Reorganization [Dated June 21, 2024] Page 21

Claim shall be sent to the following address: 

Ascentium Capital, c/o Richelle Allen, 23970 

Hwy. 59 N, Kingwood, TX 77339.

Class 1N - Secured 

Claim of Santander

R Impaired

£ Unimpaired 

Class 1N Summary. Class 1N consists of the 

Secured Claim of Santander. Santander has 

filed a proof of claim asserting it is owed 

approximately $119,428.30. The Allowed Class 

1G Claim shall be modified as set forth herein 

and paid by Reorganized Debtor as follows.

Principal Amount. The unpaid principal balance 

of the Allowed Class 1N Claim is hereby allowed 

as an Allowed Secured Claim in the amount of 

$100,000.00.

Interest. Simple interest shall accrue on the 

unpaid balance owed to the Allowed Class 1N

Claim holder at the rate of 8.29% from and after 

the Confirmation Date.

Payments. The Allowed Class 1N Claim, plus 

interest thereon, shall be paid by Reorganized 

Debtor in consecutive monthly installments of 

$2,042.00 commencing the first (1st) day of the 

first full calendar month following the Effective 

Date, and continuing on the same day each 

month thereafter until the Allowed Class 1N

Claim is paid in full.

Maturity. The maturity date shall be the first 

(1st) day of the 60th month after the first full 

calendar month following the Effective Date, at 

which time the remaining balance due and 

owing, if any, shall be paid in full.

Pre-Payment. At any time after the Effective 

Date, without penalty or premium, the Allowed 

Class 1N Claim may be prepaid, in whole or in 

part, in the sole discretion of Reorganized 

Debtor.

Collateral. Except to the extent inconsistent 

herewith or with the law, the validity and 

priority of the lien and security interest securing 

the Allowed Class 1N Claim shall remain in full 

force and effect following the Effective Date. 

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Document Page 21 of 52
Debtor’s Amended Plan of Reorganization [Dated June 21, 2024] Page 22

Default. In the event Reorganized Debtor fails 

to timely pay an Allowed Class 1N Claim 

Reorganized Debtor shall be in default, and, 

subject to Section 10.4 of the Plan, the holder 

of the affected Allowed Class 1N Claim may 

pursue remedies in accordance with that 

section.

Address for Payment. Until further notice, all 

payments due the holder of an Allowed Class 1C

Claim shall be sent to the following address: 

Santander Bank NA, 201 Old Country Road, 

Suite 120, Melville, NY 11747.

Class 1O - Secured 

Claim of American

R Impaired

£ Unimpaired 

Class 1O Summary. Class 1O consists of the 

Secured Claim of American. American has filed 

a proof of claim asserting it is owed 

approximately $91,367.63. The Allowed Class 

1G Claim shall be modified as set forth herein 

and paid by Reorganized Debtor as follows.

Principal Amount. The unpaid principal balance 

of the Allowed Class 1O Claim is hereby allowed 

as an Allowed Secured Claim in the amount of 

$91,367.63.

Interest. Simple interest shall accrue on the 

unpaid balance owed to the Allowed Class 1O

Claim holder at the rate of 8.5% from and after 

the Confirmation Date.

Payments. The Allowed Class 1O Claim, plus 

interest thereon, shall be paid by Reorganized 

Debtor in consecutive monthly installments of 

$1,540.00 commencing the first (1st) day of the 

first full calendar month following the Effective 

Date, and continuing on the same day each 

month thereafter until the Allowed Class 1O

Claim is paid in full.

Maturity. The maturity date shall be the first 

(1st) day of the 60th month after the first full 

calendar month following the Effective Date, at 

which time the remaining balance due and 

owing, if any, shall be paid in full.

Pre-Payment. At any time after the Effective 

Date, without penalty or premium, the Allowed 

Class 1O Claim may be prepaid, in whole or in 

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Document Page 22 of 52
Debtor’s Amended Plan of Reorganization [Dated June 21, 2024] Page 23

part, in the sole discretion of Reorganized 

Debtor.

Collateral. Except to the extent inconsistent 

herewith or with the law, the validity and 

priority of the lien and security interest securing 

the Allowed Class 1O Claim shall remain in full 

force and effect following the Effective Date. 

Default. In the event Reorganized Debtor fails 

to timely pay an Allowed Class 1O Claim 

Reorganized Debtor shall be in default, and, 

subject to Section 10.4 of the Plan, the holder 

of the affected Allowed Class 1O Claim may 

pursue remedies in accordance with that 

section.

Address for Payment. Until further notice, all 

payments due the holder of an Allowed Class 

1O Claim shall be sent to the following address: 

American National Bank of Texas, 102 West 

Moore Avenue, Terrell, TX 75160.

Class 1P - Secured 

Claim of Velocity

R Impaired

£ Unimpaired 

Class 1P Summary. Class 1P consists of the 

Secured Claim of Velocity. Velocity Allowed 

Claim was established pursuant to the terms of 

a final cash collateral order [Docket Entry No. 

62]. The Allowed Class 1P Claim shall be 

modified as set forth herein and paid by 

Reorganized Debtor as follows.

Principal Amount. The unpaid principal balance 

of the Allowed Class 1P Claim is hereby allowed 

as an Allowed Secured Claim in the amount of 

$135,021.40.

Interest. Simple interest shall accrue on the 

unpaid balance owed to the Allowed Class 1P

Claim holder at the rate of 0% from and after 

the Confirmation Date.

Payments. The Allowed Class 1P Claim, plus 

interest thereon, shall be paid by Reorganized 

Debtor in consecutive monthly installments of 

$7,500.00 commencing June 1, 2024, and 

continuing on the same day each month 

thereafter until the Allowed Class 1P Claim is 

paid in full.

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Document Page 23 of 52
Debtor’s Amended Plan of Reorganization [Dated June 21, 2024] Page 24

Maturity. The maturity date shall be the first 

(1st) day of the 18th month after June 1, 2024, at 

which time the remaining balance due and 

owing, if any, shall be paid in full.

Pre-Payment. At any time after the Effective 

Date, without penalty or premium, the Allowed 

Class 1P Claim may be prepaid, in whole or in 

part, in the sole discretion of Reorganized 

Debtor.

Collateral. Except to the extent inconsistent 

herewith or with the law, the validity and 

priority of the lien and security interest securing 

the Allowed Class 1P Claim shall remain in full 

force and effect following the Effective Date. 

Default. If the Debtor fails to make any such 

payment in the amount and manner provided

herein, Velocity shall provide written notice by 

mail and electronic mail to the Debtor and

undersigned counsel. The Debtor shall have a 

ten (10) day period in which to cure any alleged

defaults and if the Debtor fails to cure the 

asserted default, Velocity may proceed to 

exercise any applicable rights at that time, 

including, but not limited to seeking entry of an 

Order from the Bankruptcy Court revoking the 

use of cash collateral.

Forbearance. Notwithstanding any rights 

granted to Velocity with respect to any 

guarantors under the agreements with Velocity 

and absent any defaults under this Plan, 

Velocity shall forbear from exercising any rights 

against any and all such guarantors until the 

Allowed Class 1P Claim is paid in full

Address for Payment. Until further notice, all 

payments due the holder of an Allowed Class 1P

Claim shall be sent to the following address: 

Velocity Capital Group, LLC, 333 Pearsall Ave., 

Ste. 105, Cedarhurst, NY 11516.

Class 1Q - Secured 

Claim of Wells Fargo

R Impaired

£ Unimpaired 

Class 1Q Summary. Class 1Q consists of the 

Secured Claim of Wells Fargo. Wells Fargo has 

filed a proof of claim asserting it is owed 

approximately $175,399.86. The Allowed Class 

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Document Page 24 of 52
Debtor’s Amended Plan of Reorganization [Dated June 21, 2024] Page 25

1G Claim shall be modified as set forth herein 

and paid by Reorganized Debtor as follows.

Principal Amount. The unpaid principal balance 

of the Allowed Class 1Q Claim is hereby allowed 

as an Allowed Secured Claim in the amount of 

$108,250.00.

Interest. Simple interest shall accrue on the 

unpaid balance owed to the Allowed Class 1Q

Claim holder at the rate of 2.9% from and after 

the Confirmation Date.

Payments. The Allowed Class 1Q Claim, plus 

interest thereon, shall be paid by Reorganized 

Debtor in consecutive monthly installments of 

$1,921.00 commencing the first (1st) day of the 

first full calendar month following the Effective 

Date, and continuing on the same day each 

month thereafter until the Allowed Class 1Q

Claim is paid in full.

Maturity. The maturity date shall be the first 

(1st) day of the 60th month after the first full 

calendar month following the Effective Date, at 

which time the remaining balance due and 

owing, if any, shall be paid in full.

Pre-Payment. At any time after the Effective 

Date, without penalty or premium, the Allowed 

Class 1Q Claim may be prepaid, in whole or in 

part, in the sole discretion of Reorganized 

Debtor.

Collateral. Except to the extent inconsistent 

herewith or with the law, the validity and 

priority of the lien and security interest securing 

the Allowed Class 1Q Claim shall remain in full 

force and effect following the Effective Date. 

Default. In the event Reorganized Debtor fails 

to timely pay an Allowed Class 1Q Claim 

Reorganized Debtor shall be in default, and, 

subject to Section 10.4 of the Plan, the holder 

of the affected Allowed Class 1Q Claim may 

pursue remedies in accordance with that 

section.

Address for Payment. Until further notice, all 

payments due the holder of an Allowed Class 

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Document Page 25 of 52
Debtor’s Amended Plan of Reorganization [Dated June 21, 2024] Page 26

1Q Claim shall be sent to the following address: 

Wells Fargo Vendor Financial Services, LLC, PO 

Box 105743, Atlanta, GA 30348.

Class 1R - Secured 

Claim of Quest

R Impaired

£ Unimpaired 

Class 1R Summary. Class 1R consists of the 

Secured Claim of Quest. Quest has filed a proof 

of claim asserting it is owed approximately

$144,748.12. The Allowed Class 1G Claim shall 

be modified as set forth herein and paid by 

Reorganized Debtor as follows.

Principal Amount. The unpaid principal balance 

of the Allowed Class 1R Claim is hereby allowed 

as an Allowed Secured Claim in the amount of 

$144,748.12.

Interest. Simple interest shall accrue on the 

unpaid balance owed to the Allowed Class 1R

Claim holder at the rate of 11% from and after 

the Confirmation Date.

Payments. The Allowed Class 1R Claim, plus 

interest thereon, shall be paid by Reorganized 

Debtor in consecutive monthly installments of 

$1,494.00 commencing the first (1st) day of the 

first full calendar month following the Effective 

Date, and continuing on the same day each 

month thereafter until the Allowed Class 1R

Claim is paid in full. 

Maturity. The maturity date shall be the first 

(1st) day of the 240th month after the first full 

calendar month following the Effective Date, at 

which time the remaining balance due and 

owing, if any, shall be paid in full.

Pre-Payment. At any time after the Effective 

Date, without penalty or premium, the Allowed 

Class 1R Claim may be prepaid, in whole or in 

part, in the sole discretion of Reorganized 

Debtor.

Collateral. Except to the extent inconsistent 

herewith or with the law, the validity and 

priority of the lien and security interest securing 

the Allowed Class 1R Claim shall remain in full 

force and effect following the Effective Date. 

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Document Page 26 of 52
Debtor’s Amended Plan of Reorganization [Dated June 21, 2024] Page 27

Default. In the event Reorganized Debtor fails 

to timely pay an Allowed Class 1R Claim 

Reorganized Debtor shall be in default, and, 

subject to Section 10.4 of the Plan, the holder 

of the affected Allowed Class 1R Claim may 

pursue remedies in accordance with that 

section.

Address for Payment. Until further notice, all 

payments due the holder of an Allowed Class 1R

Claim shall be sent to the following address: 

Quest Trust Company FBO David S. Hamer IRA, 

17171 Park Row, Suite 100, Houston, TX 77084.

Class 2 - Priority Claims

excluding those in 

Article 3 of this Plan

£ Impaired

R Unimpaired

Class 2 consists of all Allowed Priority Claims 

against the Debtor. Except to the extent that 

the holder of such Claim agrees to a different 

treatment, the Reorganized Debtor shall pay 

Cash on the Effective Date to each holder of any 

Allowed Claim in Class 2 the amount of such 

Allowed Claim against such Reorganized 

Debtor.

Class 3 – Non-priority 

unsecured Claims

R Impaired

£ Unimpaired

Class 3 consists of Allowed Claims against 

Debtor (including Claims arising from the 

rejection of executory contracts and/or 

unexpired leases) other than: (i) Administrative 

Claims; (ii) Priority Tax Claims; or (iii) Claims 

included within any other Class designated in 

this Plan. Class 3 shall be deemed to include 

those Creditor(s) holding an alleged Secured 

Claim against Debtor, for which: (y) no 

collateral exists to secure the alleged Secured 

Claim; and/or (z) liens, security interests, or 

other encumbrances that are senior in priority 

to the alleged Secured Claim exceed the fair 

market value of the collateral securing such 

alleged Secured Claims as of the Petition Date.

Each holder of an Allowed Unsecured Claim in 

Class 3 shall be paid by Reorganized Debtor

from an unsecured creditor pool, which pool 

shall be funded at the rate of $1,000 per month

for 18 months and thereafter at the rate of 

$8,500 per month for 42 months. Payments 

from the unsecured creditor pool shall be paid 

quarterly, for a period not to exceed five (5) 

years (20 quarterly payments) and the first 

quarterly payment will be due on the twentieth 

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Document Page 27 of 52
Debtor’s Amended Plan of Reorganization [Dated June 21, 2024] Page 28

(20th) day of the first full calendar month 

following the last day of the first quarter. 

Estimation of Amount. Debtor estimates the 

aggregate of all Allowed Class 3 Claims is less 

than $373,000 based upon Debtor’s review of 

the Court’s claim register, Debtor’s bankruptcy 

schedules, and anticipated Claim objections.

Class 4 – Equity 

Security Holders of the 

Debtor

£ Impaired

R Unimpaired

Class 4 consists of the holders of Allowed 

Interests in the Debtor. The holder of an 

Allowed Class 4 Interest shall retain their 

interests in the Reorganized Debtor.

IF THE HOLDER OF A SECURED CLAIM DOES NOT TIMELY: (1) TENDER A BALLOT RESPECTING 

THE CONFIRMATION OF THE PLAN AND/OR (2) OBJECT TO THE CONFIRMATION OF THE 

PLAN, THAT SECURED CLAIM HOLDER IS DEEMED TO HAVE VOTED IN FAVOR OF 

CONFIRMATION.

ARTICLE 5: ALLOWANCE AND DISALLOWANCE OF CLAIMS

5.1. Disputed Claim A disputed claim is a claim that has not been allowed or 

disallowed by a final non-appealable order, and as to which 

either: 

(i) a proof of claim has been filed or deemed filed, and the Debtor 

or another party in interest has filed an objection; or 

(ii) no proof of claim has been filed, and the Debtor has scheduled 

such claim as disputed, contingent, or unliquidated.

5.2. Delay of distribution 

on a disputed Claim

No distribution will be made on account of a disputed claim 

unless such claim is allowed by a Final Order.

5.3. Settlement of 

disputed Claims

The Reorganized Debtor will have the power and authority to 

settle and compromise a disputed claim with court approval and 

compliance with Rule 9019 of the Federal Rules of Bankruptcy 

Procedure

ARTICLE 6: EXECUTORY CONTRACTS

6.1. Assumed executory 

contracts and 

unexpired leases

(a) Reorganized Debtor assumes the following executory 

contracts and/or unexpired leases effective upon the Effective 

Date:

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Debtor’s Amended Plan of Reorganization [Dated June 21, 2024] Page 29

• See attached Exhibit “C”

(b) Reorganized Debtor will be conclusively deemed to have 

rejected all executory contracts and/or unexpired leases not 

expressly assumed under section 6.1(a) above, or before the date 

of the order confirming this Plan, upon the date of the entry of 

the order confirming this Plan. A proof of claim arising from the 

rejection of an executory contract or unexpired lease under this 

section must be filed no later than ninety (90) days after the 

Effective Date.

ARTICLE 7: MEANS FOR IMPLEMENTATION OF THE PLAN

7.1. General The Debtor proposes to implement and consummate this Plan 

through the means contemplated by §§ 1123 and 1145(a) of the 

Bankruptcy Code.

7.2. Reorganized Debtor 

and Performance of 

Assumed Executory 

Contracts

From and after the Effective Date, in accordance with the terms 

of this Plan and the Confirmation Order, the Reorganized Debtor 

shall perform all obligations under all executory contracts and 

unexpired leases assumed in accordance with Article 6 of this 

Plan.

7.3. Reorganized Debtor 

and Estate assets

7.3.1. Management of Reorganized Debtor. The 

management of Reorganized Debtor will remain unaltered.

7.3.2. Revesting [§ 1191(a)]. On the Effective Date, if 

the Plan is confirmed pursuant to § 1191(a), title to all assets, 

claims, Causes of Action, properties, and business operations of 

the Debtor and of the Estate shall vest and/or revest in the 

Reorganized Debtor. Thereafter, each Reorganized Debtor shall 

own and retain such assets free and clear of all liens and Claims, 

except as expressly provided in this Plan. From and after the 

Effective Date, except as otherwise described in this Plan, each 

Reorganized Debtor shall own and operate such assets without 

further supervision by or jurisdiction of this Court, except as 

otherwise provided herein.

7.3.3. No Revesting [§ 1191(b)]. If the Plan is confirmed 

pursuant to § 1191(b), title to all assets, claims, Causes of Action, 

properties, and business operations of the Debtor and of the 

Estate shall remain property of the Estate until discharge of the 

Reorganized Debtor pursuant to § 1192. From and after the 

Discharge Date title to all assets, claims, Causes of Action, 

properties, and business operations of the Debtor and of the 

Estate shall vest and/or revest in the Reorganized Debtor. 

Thereafter, each Reorganized Debtor shall own and retain such 

assets free and clear of all liens and Claims, except as expressly 

provided in this Plan. From and after the Discharge Date, except 

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Debtor’s Amended Plan of Reorganization [Dated June 21, 2024] Page 30

as otherwise described in this Plan, each Reorganized Debtor 

shall own and operate such assets without further supervision by 

or jurisdiction of this Court, except as otherwise provided herein.

7.3.4. Disbursing Agent. If the Plan is confirmed under 

§ 1191(a) of the Bankruptcy Code the Reorganized Debtor shall 

serve as the disbursing agent, without bond, for purposes of 

making transfers and payments under this Plan. If the Plan is 

confirmed under § 1191(b) of the Bankruptcy Code the disbursing 

agent shall be:

£ SubV Trustee of the Reorganized Debtor

R The Reorganized Debtor as request is hereby made 

pursuant to § 1194(b) of the Bankruptcy Code.

7.4. Settlement of 

disputed Claims

The Reorganized Debtor will each have the power and authority 

to settle and compromise a disputed claim with court approval 

and compliance with Rule 9019 of the Federal Rules of 

Bankruptcy Procedure respecting the Estate.

ARTICLE 8: GENERAL PROVISIONS

8.1. Definitions The definitions set forth in § 101 of the Code shall apply when 

terms defined or construed in the Code are used in this Plan, and

they are supplemented by the following definitions:

8.1.1. Ad Valorem Tax Authorities means the following:

• Kaufman County

• McLennan County

• Forny ISD

8.1.2. Administrative Claim means any right to payment 

constituting a cost or expense of administration of the Case of a 

kind specified under § 503(b) of the Bankruptcy Code and entitled 

to priority under §§ 507(a)(2), 507(b) or 1114(e)(2) of the 

Bankruptcy Code, including, without limitation: (i) any actual and 

necessary costs and expenses of preserving the Estate of the 

Debtor; (ii) any actual and necessary costs and expenses of 

operating any of the Debtor’s business enterprises; (iii) any 

indebtedness or obligations incurred or assumed by the Debtor 

in connection with the conduct of its business enterprise; (iv) all 

compensation and reimbursement of expenses to the extent 

awarded by the Court under §§ 330, 331 or 503 of the Bankruptcy 

Code; (v) any fees or charges assessed against the Estate under § 

1930 of chapter 123 of title 28 of the United States Code; and (vi) 

any Claim for goods delivered to the Debtor within twenty days 

of the Petition Date and entitled to administrative priority 

pursuant to § 503(b)(9) of the Bankruptcy Code.

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Debtor’s Amended Plan of Reorganization [Dated June 21, 2024] Page 31

8.1.3. Allowed Amount means the amount in lawful 

currency of the United States of any Allowed Claim, or the 

number of shares representing any Allowed Interest.

8.1.4. Allowed means, with reference to any Claim or 

Interest: (i) a Claim against or Interest in the Debtor, proof of 

which, if required, was filed on or before the Bar Date, which is 

not a Contested Claim or Contested Interest; (ii) if no proof of 

claim or interest was so filed, a Claim against or Interest in the 

Debtor that has been or hereafter is listed by the Debtor in the 

Schedules as liquidated in amount and not disputed or 

contingent as such Schedules may be amended from time to time 

in accordance with Bankruptcy Rule 1009; or (iii) a Claim or 

Interest allowed hereunder or by Final Order. Moreover, the 

following Claims or Interests are not Allowed: (i) any Claim or 

Interest allowed solely for the purpose of voting to accept or 

reject the Plan pursuant to an order of the Court; (ii) any Claim or 

Interest, or any portion thereof, which is subsequently 

withdrawn, disallowed, released or waived by the holder thereof, 

by this Plan, or pursuant to a Final Order; and (iii) any Claim or 

Interest, or any portion thereof, which is attributable to punitive 

damages or penalties.

8.1.5. Ally 5710 means Ally Bank as it relates to Account 

number ending in 5769.

8.1.6. Ally 5790 means Ally Bank as it relates to Account 

number ending in 4892.

8.1.7. Ally 4928 means Ally Bank as it relates to Account 

number ending in 8959.

8.1.8. Avoidance Action means any claim or cause of 

action belonging to the Debtor and arising under the Bankruptcy 

Code including, but not limited to, §§ 544, 547, 548 and 550.

8.1.9. Ballot means each of the ballot forms distributed 

to each holder of an impaired Claim or Interest (other than to 

holders not entitled to vote on the Plan) upon which is to be 

indicated, among other things, acceptance or rejection of the 

Plan.

8.1.10. Bankruptcy Code means Title 11 of the United 

States Code, 11 U.S.C. §§ 101 et seq., as in effect on the date 

hereof.

8.1.11. Bankruptcy Court means the United States 

Bankruptcy Court for the Eastern District of Texas, Sherman 

Division.

8.1.12. Bankruptcy Rules means the Federal Rules of 

Bankruptcy Procedure as promulgated by the United States 

Supreme Court under § 2075 of title 28 of the United States Code, 

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Debtor’s Amended Plan of Reorganization [Dated June 21, 2024] Page 32

and local rules of the Court, as the context requires, and as in 

effect on the date hereof.

8.1.13. Bar Date means the deadline by which a Claim 

must have been timely filed. The Bar Date for all Administrative 

Claims is the date that is ninety (90) days after the Effective Date.

8.1.14. Beacon means Beacon Funding Corporation.

8.1.15. Business Day means any day other than a 

Saturday, a Sunday or a “legal holiday” as that phrase is defined 

in Bankruptcy Rule 9006(a).

8.1.16. Case means the above entitled and numbered 

case which was commenced by the Debtor filing of a voluntary 

petition for relief pursuant to the Bankruptcy Code.

8.1.17. Causes of Action means any and all claims, rights 

and causes of action that have been or could have been brought 

by or on behalf of the Debtor arising before, on or after the 

Petition Date, known or unknown, in contract or in tort, at law or 

in equity or under any theory of law, including, but not limited to 

any and all claims, rights and causes of action the Debtor or the 

Estate may have against any Person arising under chapter 5 of the 

Bankruptcy Code, or any similar provision of state law or any 

other law, rule, regulation, decree, order, statute or otherwise, 

including but not limited to any claim or cause of action under a 

policy of insurance, claims, if any, against officers and directors 

of the Debtor, Avoidance Actions under the Code, and any other 

causes of action belonging to the Debtor or the Estate.

8.1.18. Claim means: (i) right of payment, whether or not 

such right is reduced to judgment, liquidated, unliquidated, fixed, 

contingent, matured, unmatured, disputed, undisputed, legal, 

equitable, secured or unsecured; or (ii) a right to an equitable 

remedy for breach of performance if such breach gives rise to a 

right of payment, whether or not such right to an equitable 

remedy is reduced to judgment, fixed, contingent, matured, 

unmatured, disputed, undisputed, secured or unsecured.

8.1.19. Claimant means the holder of a Claim or Interest.

8.1.20. Claims Objection Deadline means the date by 

which parties authorized by the Plan may file any objection to a 

Claim, which date shall be ninety (90) days after the Effective 

Date, except with respect to Administrative Claims as otherwise 

provided for herein.

8.1.21. Class means all of the holders of Claims or 

Interests with respect to the Debtor that has been designated as 

a class in Article 4 hereof.

8.1.22. Confirmation means the entry by the Bankruptcy 

Court of the Confirmation Order.

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Debtor’s Amended Plan of Reorganization [Dated June 21, 2024] Page 33

8.1.23. Confirmation Date means the date of entry by the 

Bankruptcy Court of an order confirming the Plan.

8.1.24. Confirmation Hearing means the hearing or 

hearings to be held before the Bankruptcy Court in which the 

Debtor shall seek Confirmation of this Plan.

8.1.25. Confirmation Order means the Final Order 

confirming this Plan.

8.1.26. Contested when used with respect to a Claim or 

Interest, means a Claim against or Interest in the Debtor that is: 

(i) listed in any of the Debtor’s Schedules as disputed, contingent, 

or unliquidated and as to which a proof of claim has been timely 

filed; (ii) listed in any of the Debtor’s Schedules as undisputed, 

liquidated, and not contingent and as to which a proof of Claim 

or Interest has been filed with the Bankruptcy Court, to the 

extent the proof of Claim or Interest amount exceeds the amount 

provided for in any of the Debtor’s Schedules; or (iii) the subject 

of an objection which has been or may be timely filed by any 

party in interest or the United States Trustee and which claim has 

not been disallowed by Final Order. To the extent an objection 

relates to the allowance of only a part of a Claim or Interest, such 

a Claim or Interest shall be a Contested Claim or Contested 

Interest only to the extent of the objection.

8.1.27. Creditor means holder of a Claim as of the Petition 

Date.

8.1.28. Debtor means, One More Recovery, LLC.

8.1.29. Discharge Date means the date the Reorganized 

Debtor attains a discharge under § 1192 of the Bankruptcy Code.

8.1.30. Entity includes any individual, partnership, 

corporation, estate, trust, governmental unit, person, and the 

United States Trustee.

8.1.31. Estate means the bankruptcy estate of the Debtor 

created by Section 541 of the Bankruptcy Code upon the 

commencement of this Case.

8.1.32. Final Order means: (i) an order of the Bankruptcy 

Court as to which the time to appeal, petition for certiorari, or 

move for reargument or rehearing has expired and as to which 

no appeal, petition for certiorari, or other proceedings for 

reargument or rehearing, shall then be pending or, (ii) in the 

event that an appeal, writ of certiorari, reargument or rehearing 

thereof has been sought, such order of the Bankruptcy Court 

shall have been affirmed by the highest court to which such order 

may be appealed, or certiorari has been denied, and the time to 

take any further appeal, petition for certiorari or move for 

reargument or rehearing shall have expired; provided, however, 

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Debtor’s Amended Plan of Reorganization [Dated June 21, 2024] Page 34

that the Confirmation Order may be treated as a Final Order if no 

stay pending appeal has been obtained.

8.1.33. First Citizens 0727 means First Citizens Bank & 

Trust, as it relates to account ending in 0727.

8.1.34. First Citizens 0525 means First Citizens Bank & 

Trust, as it relates to account ending in 0525.

8.1.35. First Citizens 1946 means First Citizens Bank & 

Trust, as it relates to account ending in 1946.

8.1.36. Fora means Fora Financial Asset Securitization 

2021, LLC.

8.1.37. Hartzendorf means Beverly Hartzendorf.

8.1.38. Initial Distribution Date means the first Business 

Day on which a distribution is made under the Plan to holders of 

Allowed Claims.

8.1.39. Insider means: (i) a director of the Debtor; (ii) an 

officer of the Debtor; (iii) a person in control of the Debtor; (iv) a 

partnership in which the Debtor is general partner; (v) a general 

partner of the Debtor; (vi) a relative of a general partner in, 

general partner of, or person in control of the Debtor, (vii) an 

affiliate (defined in § 101(2) of the Bankruptcy Code) of the 

Debtor or an Insider of an affiliate as if such affiliate were a 

Debtor; and (viii) a managing agent of the Debtor.

8.1.40. Interest means: (i) the membership interests or 

ownership interests in the Debtor; and (ii) any right or option, 

however arising, to acquire a membership interest or any other 

equity interest in the Debtor.

8.1.41. IRS means the Internal Revenue Service.

8.1.42. Lien means all valid and enforceable liens, security 

interests, claims and encumbrances against any property of the 

Debtor’s estate, which is permitted by, or not avoided pursuant 

to the Bankruptcy Code.

8.1.43. Pawnee means Pawnee Leasing Corporation.

8.1.44. Petition Date means March 22, 2024, the date the 

Debtor filed a voluntary bankruptcy petition commencing this

Case.

8.1.45. Plan means this “Amended Plan of 

Reorganization [Dated June 21, 2024]”, including all exhibits and 

attachments, each of which is hereby incorporated and made 

part thereof, as modified or amended from time to time in 

accordance with § 1127 of the Bankruptcy Code. 

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Debtor’s Amended Plan of Reorganization [Dated June 21, 2024] Page 35

8.1.46. Plan Rate means the Prime Rate as of the Effective 

Date or such other rate of interest as is determined by the 

Bankruptcy Court.

8.1.47. Plan Term means the duration of the Plan which 

in this case is five (5) years from and after the Effective Date.

8.1.48. Prime Rate means the prime interest rate quoted 

and published from time-to-time in the "Money Rates" section of 

the Wall Street Journal.

8.1.49. Priority Claim means all Claims entitled to priority 

under §§ 507(a)(2)-(a)(7) and (a)(9)-(a)(10) of the Bankruptcy 

Code.

8.1.50. Priority Tax Claim means all Claims for Taxes 

entitled to priority under § 507(a)(8) of the Bankruptcy Code, and 

shall include all Tax Claims secured by assets of the Estate.

8.1.51. Pro Rata means proportionately, so that with 

respect to a particular Allowed Claim, the ratio of: (i) the monies 

or property disbursed on account of such Allowed Claim to the 

amount of such Allowed Claim, is the same as the ratio of (ii) the 

monies or property disbursed on account of all Allowed Claims of 

the Class in which such Allowed Claim is included to the amount 

of all Allowed Claims in that Class.

8.1.52. Professionals means those Entities: (i) employed 

under §§ 327 or 1103 of the Bankruptcy Code; and (ii) entitled, 

under §§ 330, 503(b), 506(b), and 507(a)(2) of the Bankruptcy 

Code, to seek compensation for legal, accounting and/or other 

professional services and the costs and expenses related to such 

services from the Debtor and/or the Estate.

8.1.53. Quest means Quest Trust Company FBO David S. 

Hamer IRA #1382121.

8.1.54. Regions means Regions Bank dba Ascentium 

Capital LLC.

8.1.55. Rejection Damages Deadline means the later of 

the Bar Date, or thirty (30) days after the entry of an order 

approving the rejection of an executory contract or unexpired 

lease.

8.1.56. Reorganized Debtor means, One More Recovery, 

LLC, after the entry of the Confirmation Order.

8.1.57. Santander means Santander Bank NA.

8.1.58. Schedules means those schedules, statements 

and lists filed with the Court by the Debtor pursuant to and in 

accord with § 521(a)(1) of the Bankruptcy Code and Bankruptcy 

Rule 1007(b).

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Debtor’s Amended Plan of Reorganization [Dated June 21, 2024] Page 36

8.1.59. Secured Claim means a Claim secured by a Lien on 

any property of the Estate, but only to the extent of the value of 

the interest of the holder of such Claim in the interest of the 

subject Estate in such property, the calculation of which shall not 

include any demand for default interest, penalty interest or other 

similar demands.

8.1.60. Springer means Mayre Springer.

8.1.61. State Comptroller means the Texas Comptroller 

of Public Accounts.

8.1.62. Subordinated Claim means: (i) any Claim, or 

portion of a Claim, that is subject to subordination under § 510 

of the Bankruptcy Code; and (ii) any Claim, or portion of a Claim, 

for fines, penalties, forfeitures, for multiple, exemplary, or 

punitive damages, or other non-pecuniary, direct or nonproximate damages.

8.1.63. SubV Trustee means individual appointed as 

trustee under § 1183 of the Bankruptcy Code.

8.1.64. Tax means and includes any federal state, county 

and local income, ad valorem, excise, stamp and other tax of any 

type or nature whatsoever.

8.1.65. Tax Claim means any and all Secured or Priority 

Claims of the Debtor for the payment of any Taxes: (i) accorded a 

priority pursuant to § 507(a)(8) of the Code; or (ii) secured by 

valid Liens on property of the Estate existing on the Confirmation 

Date.

8.1.66. Velocity means Velocity Capital Group, LLC.

8.1.67. Wells Fargo means Wells Fargo Vendor Financial 

Services, LLC.

8.1.68. United States Trustee means the Office of the 

United States Trustee for Region Six.

8.1.69. Unsecured Claim means a Claim that is not an 

Administrative Claim, a Priority Claim, a Priority Tax Claim, or a 

Secured Claim.

8.2. Effective Date The date on which the Confirmation Order becomes a Final 

Order.

8.3. Severability If any provision of this Plan is determined to be unenforceable, 

the determination will in no way limit or affect the enforceabililty 

and operative effect on any other provision of this Plan.

8.4. Binding Effect The rights and obligations of any entity named or referred to in 

this Plan will be binding upon, and will inure to the benefit of the 

successors or assigns of such entity.

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Debtor’s Amended Plan of Reorganization [Dated June 21, 2024] Page 37

8.5. Captions The headings contained in this Plan are for convenience of 

reference only and do not affect the meaning or interpretation of 

this Plan.

8.6. Controlling Effect Unless a rule of law or procedure is supplied by federal law 

(including the Code or the Federal Rules of Bankruptcy 

Procedure), the laws of the State of Texas govern this Plan and 

any agreements, documents, and instruments executed in 

connection with this Plan, except as otherwise provided for in this 

Plan.

8.7. Corporate 

Governance

The management of each Reorganized Debtor will remain 

unaltered.

8.8. Retention of 

Jurisdiction

The Bankruptcy Court shall retain exclusive jurisdiction over this 

Case after Confirmation, notwithstanding consummation or 

substantial consummation, for the following purposes:

8.8.1. to consider and effect any modification of this Plan 

under § 1127 of the Bankruptcy Code;

8.8.2. to hear and determine all controversies, suits and 

disputes that arise in connection with the interpretation, 

implementation, effectuation, consummation or enforcement of 

this Plan;

8.8.3. to hear and determine all requests for 

compensation and/or reimbursement of expenses for the period 

commencing on the Petition Date through the Confirmation 

Date;

8.8.4. to hear and determine all objections to Claims and 

Interests, and to determine the appropriate classification of any 

Claim or Interest, and other controversies, suits and disputes that 

may be pending at or initiated after the Confirmation Date, 

except as provided in the Confirmation Order;

8.8.5. to hear and determine all claims that the Debtor, 

as debtor in possession qua trustee, could assert under the 

Bankruptcy Code;

8.8.6. to consider and act on such other matters 

consistent with this Plan as may be provided in the Confirmation 

Order;

8.8.7. to make such orders as are necessary and 

appropriate to carry out and implement the provisions of this 

Plan;

8.8.8. to approve the reasonableness of any payments 

made or to be made, within the meaning of § 1129(a)(4) of the 

Bankruptcy Code;

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Debtor’s Amended Plan of Reorganization [Dated June 21, 2024] Page 38

8.8.9. to exercise the jurisdiction granted pursuant to §§ 

505(a) and (b) of the Bankruptcy Code to determine any and all 

federal, state, local and foreign tax liabilities of, and any and all 

refunds of such taxes paid by the Debtor;

8.8.10. to hear and determine any issues or matters in 

connection with any property not timely claimed as provided in 

this Plan;

8.8.11. to hear and determine any controversies with 

respect to any settlements approved by the Bankruptcy Court; 

8.8.12. to determine any and all motions, applications, 

adversary proceedings and contested matters whether pending 

in the Case as of the Effective Date or brought subsequently by 

the Reorganized Debtor; and

8.8.13. to enter a final decree closing any or all Cases.

8.8.14. Failure of the Bankruptcy Court to Exercise 

Jurisdiction. If the Bankruptcy Court abstains from exercising or 

declines to exercise jurisdiction over any matter arising under, in 

or related to the Debtor’s Estate, including with respect to the 

matters set forth herein, this Article 8 shall not prohibit or limit

the exercise of jurisdiction by any other court having competent 

jurisdiction with respect to such matter.

8.9. Rules of 

construction

The rules of construction set forth in § 102 of the Code shall 

apply and are supplemented as follows:

8.9.1. The words “herein,” “hereof,” “hereto,” 

“hereunder,” and other words of similar import refer to the Plan 

as a whole and not to any particular article, section, subsection 

or clauses contained in the Plan.

8.9.2. Unless otherwise specified, a reference to an 

article or a section is a reference to that article or section of the 

Plan.

8.9.3. Any reference in the Plan to a document being in 

a particular for or on particular terms and conditions meant that 

the document shall be substantially in such form or substantially 

on such terms and conditions.

8.9.4. Any reference in the Plan to an existing document 

means such document, as it may have been amended, modified 

or supplemented from time to time as of the Effective Date.

8.10. All headings utilized in this Plan are for convenience and 

reference only, and shall not constitute a part of this Plan for any 

other purpose.

ARTICLE 9: DISCHARGE

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Debtor’s Amended Plan of Reorganization [Dated June 21, 2024] Page 39

DISCHARGE IF PLAN IS CONFIRMED UNDER § 1191(a) OF THE 

BANKRUPTCY CODE

£

Discharge if the Debtor is an individual and § 1141(d)(3) is not 

applicable. Confirmation of this Plan does not discharge any debt 

provided for in this Plan until the court grants a discharge on 

completion of all payments under this Plan, or as otherwise 

provided in § 1141(d)(5) of the Code. The Debtor will not be 

discharged from any debt excepted from discharge under § 523 

of the Code, except as provided in Rule 4007(c) of the Federal 

Rules of Bankruptcy Procedure.

£

Discharge if the Debtor is a partnership and § 1141(d)(3) is not 

applicable. On the Effective Date, the Debtor will be discharged 

from any debt that arose before confirmation of this Plan, to the 

extent specified in § 1141(d)(1)(A) of the Code. The Debtor will 

not be discharged from any debt imposed by this Plan.

R

Discharge if the Debtor is a corporation and § 1141(d)(3) is not 

applicable. On the Effective Date, the Debtor will be discharged 

from any debt that arose before confirmation of this Plan, to the 

extent specified in § 1141(d)(1)(A) of the Code, except that the 

Debtor will not be discharged of any debt: 

(i) imposed by this Plan; or 

(ii) to the extent provided in § 1141(d)(6).

£

No discharge if § 1141(d)(3) is applicable. In accordance with § 

1141(d)(3) of the Code, the Debtor will not receive any discharge 

of debt in this bankruptcy case.

DISCHARGE IF PLAN IS CONFIRMED UNDER § 1191(b) OF THE 

BANKRUPTCY CODE

If the Plan is confirmed under section 1191(b) of this title, as soon 

as practicable after completion by the Debtor of all payments due 

within the Plan Term, the Court shall grant the Debtor a discharge 

of all debts provided in §§ 503 and 1141(d)(1)(A) of the 

Bankruptcy Code to the extent provided for in the Plan, except 

any debt: (1) on which the last payment is due after the Plan 

Term; or (2) of the kind specified in § 523(a) of the Bankruptcy 

Code.

ARTICLE 10: OTHER PROVISIONS

10.1. Conditions to 

Consummation

The following are conditions precedent to the occurrence of the 

Effective Date, each of which must be satisfied or waived by the 

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Debtor’s Amended Plan of Reorganization [Dated June 21, 2024] Page 40

Debtor:

10.1.1. The Confirmation Order must have become a Final 

Confirmation Order.

10.1.2. No request for revocation of the Confirmation 

Order under § 1144 of the Bankruptcy Code shall have been 

made, or, if made, shall remain pending; and

10.1.3. All actions, documents and agreements necessary 

to implement the Plan shall have been effectuated or executed.

10.1.4. Waiver of Conditions. Each of the conditions set 

forth above may be waived in whole or in part by the Debtor in 

its sole and absolute discretion, without any notice to parties in 

interests or the Bankruptcy Court, and without a hearing. The 

Debtor’s waiver of any one condition shall not be deemed a 

waiver of any other condition.

10.2. Binding Effect Except as otherwise provided in § 1141(d) of the Bankruptcy 

Code, on and after the Confirmation Date, the provisions of this 

Plan shall bind any holder of a Claim against or Interest in the 

Debtor and such holder’s respective successors and assigns, 

whether or not the Claim or Interest of such holder is impaired 

under the Plan and whether or not such holder has accepted the 

Plan.

10.3. Injunction 10.3.1. Permanent Injunction. Except as otherwise 

expressly provided in, or permitted under, this Plan, all Creditors 

and Interest holders, are permanently enjoined on and after the 

Effective Date against the collecting of Claims against the 

Reorganized Debtor or any guarantors in any manner other than 

as provided for in the Plan. 

10.3.2. The injunction provisions set forth herein do not 

enjoin the prosecution of any claims that arise on or after the 

Effective Date nor does it enjoin the determination of the 

Allowed Amount of any Claims that arose prior to the Effective 

Date by a court of competent jurisdiction.

10.4. Notice of Default Notice of Default. Except as otherwise provided herein with 

respect to the treatment of a Class of Creditors, in the event of 

any alleged default under the Plan, any Creditor or party-ininterest must give a written default notice to the defaulting

Reorganized Debtor with copies to counsel of record for the 

defaulting Reorganized Debtor specifying the nature of the 

default. Upon receipt of the default notice, the defaulting 

Reorganized Debtor shall have ten (10) days to cure such default 

from the time of receipt of the default notice. If such default has 

not been cured within the applicable time period any such 

Creditor or party-in-interest shall have the right to exercise any 

and all available remedies, including the right to undertake 

Case 24-30808-sgj11 Doc 74 Filed 06/21/24 Entered 06/21/24 18:46:23 Desc Main

Document Page 40 of 52
Debtor’s Amended Plan of Reorganization [Dated June 21, 2024] Page 41

foreclosure upon any collateral securing the obligation, if 

applicable. 

10.5. Miscellaneous 10.5.1. Request for Relief Under Section 1191(b). In the 

event any Class of Creditors or Interests shall fail to accept this 

Plan in accordance with §§ 1129(a) and 1191(a) of the 

Bankruptcy Code, the Debtor requests the Bankruptcy Court to 

confirm this Plan in accordance with the provisions of § 1191(b) 

of the Bankruptcy Code.

10.5.2. Incorporation of Rule 9019. To the extent 

necessary to effectuate and implement the compromises and 

releases contained in this Plan, the Plan shall be deemed to 

constitute a motion under Bankruptcy Rule 9019 seeking the 

Bankruptcy Court’s approval of all of the compromises and 

releases contained herein.

10.5.3. Computation of Time. The computation of any 

time periods prescribed or allowed by the Plan shall be governed 

by Bankruptcy Rule 9006.

10.5.4. Exhibits. All exhibits to the Plan are incorporated 

into the Plan and shall be deemed to be part of the Plan.

10.5.5. Modification. The Debtor may alter, amend or 

modify this Plan under § 1127 of the Bankruptcy Code or as 

otherwise permitted by law prior to Confirmation. Further, the 

Reorganized Debtor may also seek to modify the Plan after 

Confirmation and prior to substantial consummation of the Plan 

so long as the treatment of the holders of Allowed Claims or 

Interests are not materially or adversely affected.

10.6. Due Authorization. Each and every Claim and Interest 

holder who elects to participate in the distributions provided for 

herein warrant that such Claim or Interest holder is authorized to 

accept, in consideration of such Claim against or Interest in the 

Debtor, the distributions provided for in this Plan and that there 

are not outstanding commitments, agreements, or 

understandings, expressed or implied, that may or can in any way 

defeat or modify the rights conveyed or obligations undertaken 

by such Claim or Interest holder under this Plan.

10.7. Authorization of Corporate Action. All matters and 

actions provided for under this Plan involving the structure of the 

Debtor or action to be taken by or required of the Debtor or 

Reorganized Debtor shall be deemed to have occurred and be 

effective as provided herein, and shall be deemed to be 

authorized and approved in all respects without any requirement 

for further action by the members or partners of the Debtor, as 

applicable.

10.8. Further Assurances and Authorizations. The Debtor

and/or the Reorganized Debtor, if and to the extent necessary, 

Case 24-30808-sgj11 Doc 74 Filed 06/21/24 Entered 06/21/24 18:46:23 Desc Main

Document Page 41 of 52
Debtor’s Amended Plan of Reorganization [Dated June 21, 2024] Page 42

shall seek such orders, judgments, injunctions, and rulings that 

may be required to carry out further the intentions and purposes, 

and to give full effect to the provisions, of this Plan. 

10.9. Privileged Communications; Work Product. For 

purposes of any proprietary, confidential or privileged 

information or communication, including attorney-client 

privileged communications, and documents that would 

otherwise constitute attorney work product, the Reorganized 

Debtor shall succeed to the interest of the Debtor and Estate, to 

the extent provided by applicable law.

10.10. No Interest. Except as expressly stated in this Plan, or 

allowed by the Bankruptcy Court, no interest, penalty or late 

charge is to be allowed on any Claim subsequent to the Petition 

Date.

10.11. No Attorneys' Fees. No attorneys’ fees will be paid with 

respect to any Claim, other than Claims of professionals 

employed by the Debtor, except as specified herein or as allowed 

by a prior order of the Bankruptcy Court.

10.12. Post-Confirmation Actions. After Confirmation, the 

Reorganized Debtor may, with the approval of the Bankruptcy 

Court, and so long as it does not materially or adversely affect the 

interest of Creditors, remedy any defect or omission, or reconcile 

any inconsistencies in this Plan or in the Confirmation Order, in 

such manner as may be necessary to carry out the purposes and 

effect of this Plan.

10.13. Post-Confirmation Conversion and/or Dismissal. Any 

Creditor or interested party, in the event of a default under the 

terms of this Plan, may file a motion to dismiss or convert this 

case pursuant to § 1112 of the Bankruptcy Code after the Plan is 

confirmed if the Case has not been closed or the Plan confirmed 

pursuant under section 1191(b). If the Bankruptcy Court orders 

the case converted to one under Chapter 7, then all property that 

had been property of the chapter 11 bankruptcy estate, and not 

previously disbursed under the terms of this Plan, shall revest in 

the Chapter 7 bankruptcy estate. Further, to the extent relief 

from stay had not previously been granted during the chapter 11 

bankruptcy process, a new automatic stay shall be reimposed 

upon all property of the Chapter 7 bankruptcy estate.

10.14. Post-Confirmation Removal of Reorganized Debtor. In 

the event the Reorganized Debtor fails to perform its obligations 

under the confirmed Plan, the Court shall order the Reorganized 

Debtor to be removed as a debtor-in-possession in accord with § 

1185(a) of the Bankruptcy Code and the SubV Trustee shall 

perform the duties specified in § 704(a)(8) of the Bankruptcy 

Code and paragraphs (1), (2), and (6) of § 1106(a) of this title, 

Case 24-30808-sgj11 Doc 74 Filed 06/21/24 Entered 06/21/24 18:46:23 Desc Main

Document Page 42 of 52
Debtor’s Amended Plan of Reorganization [Dated June 21, 2024] Page 43

including operating the business of the debtor in accord with § 

1183(b)(5) of the Bankruptcy Code.

10.14.1. Should this Plan be confirmed pursuant to 

§ 1191(a) of the Bankruptcy Code any and all property that vests 

in the Reorganized Debtor under the terms of this Plan shall vest 

and/or revest in the Reorganized Debtor’s Estate in the event the 

Reorganized Debtor is removed under § 1185(a) of the 

Bankruptcy Code. 

10.15. Minimum Distribution. Notwithstanding anything to the 

contrary in this Plan, the Reorganized Debtor shall be required to 

make distributions under this Plan of a sum less than $100.00 to 

any Allowed Claim holder. In such case, the Allowed Amount of 

such Claims shall be reduced to zero and such funds shall be 

retained by the Reorganized Debtor.

10.16. Substantial Consummation. If the Plan is confirmed 

pursuant to § 1191(a) of the Bankruptcy Code, substantial 

consummation shall be deemed to occur when the Reorganized 

Debtor makes initial distributions pursuant to the terms of the 

Plan.

10.17. Notices. All notices, requests, elections or demands in 

connection with the Plan shall be in writing and shall be deemed 

to have been given when received or, if mailed, five (5) days after 

the date of mailing provided such writing shall have been sent by 

registered or certified mail, postage prepaid, return receipt 

requested. Any notices required to be delivered to the Debtor 

shall be addressed as follows:

To Debtor and/or Reorganized Debtor:

One More Recovery, LLC

Attention: Tana Patterson

6842 Michael Talty Ave.

Terrell, TX 75160

With a copy to:

Robert T. DeMarco

DeMarco Mitchell, PLLC

12770 Coit Road, 850

Dallas, TX 75251

10.18. Notices and Distributions. On and after the Effective 

Date, all notices, requests and distributions to Claimants shall be 

sent to the last known address of: (1) the Claimant or its/his/her 

attorney of record as reflected in the Claimant’s proof of claim; 

or (2) if there is no such evidence of a last known address, to the 

last known address of the Claimant according to the books and 

records of either Debtor. Any Claimant may designate another 

address for the purposes of this Section by providing the subject 

Case 24-30808-sgj11 Doc 74 Filed 06/21/24 Entered 06/21/24 18:46:23 Desc Main

Document Page 43 of 52
Debtor’s Amended Plan of Reorganization [Dated June 21, 2024] Page 44

Reorganized Debtor written notice of such address, which notice 

will be effective upon receipt by said Reorganized Debtor.

10.19. Unclaimed Property. If any property distributed under 

the Plan by the Reorganized Debtor remains unclaimed for a 

period of two (2) years the initial date of the attempted delivery 

such unclaimed property shall be forfeited by the Claimant and 

the unclaimed property and the right to receive it shall revert to 

and vest in the subject Reorganized Debtor free and clear of any 

claims, rights or interests. Said Reorganized Debtor, on the 

anniversary of the Effective date, shall file with the Bankruptcy 

Court a schedule that identifies the name and last-known address 

of all holders of unclaimed distributions.

10.20. Setoff. Except as specifically provided in the Plan, no 

Creditor shall retain any contractual or statutory right to set off 

any asset in which either Debtor or Reorganized Debtor has an 

interest in satisfaction of that Creditor’s pre-petition Claim. Any 

right to set off a claim against an asset of either Debtor or 

Reorganized Debtor which is not specifically retained is waived. 

10.21. No Admissions. Notwithstanding anything herein to the 

contrary, nothing contained in this Plan shall be deemed an 

admission by the Plan Proponents with respect to any matter set 

forth herein, including, without limitation, liability on any Claim 

or Interest or the propriety, any classification of any Claim or 

Interest, or the valuation of any property.

Dated: June 21, 2024

Respectfully submitted,

/s/ Tana Patterson

Tana Patterson

Managing Member,

One More Recovery, LLC

Presented by:

/s/ Robert T. DeMarco

DeMarco•Mitchell, PLLC

Robert T. DeMarco, Texas Bar No. 24014543

Email robert@demarcomitchell.com

Michael S. Mitchell, Texas Bar No. 00788065

Email mike@demarcomitchell.com

12770 Coit Road, 850

Dallas, TX 750251

T 972-991-5591

F 972-346-6791

Attorneys for the Debtor and 

Debtor-in-Possession

Case 24-30808-sgj11 Doc 74 Filed 06/21/24 Entered 06/21/24 18:46:23 Desc Main

Document Page 44 of 52
EXHIBIT “A”

A. CHAPTER 7 DIVIDENDS PAID. The Debtor makes the following assumptions:

ASSET LIQUIDATION VALUE LIEN NET ASSET VALUE

A/R $65,000.002 $137,000.00 $0.00

Equipment $799,500.003 $1,900,000.00 $0.00

Real Property $731,000.004 $720,000.00 $11,000.00

TOTAL $0.00

As set forth in the above table, Debtor asserts the liquidation value of the Debtor’s NONEXEMPT 

collective assets, net of secured liens, is approximately $0.00. 

B. PLAN DIVIDENDS PAID. The Debtor makes the following assumptions:

ASSUMPTION COST

The Debtor is able to continue operating through the Plan Term and 

will meet or exceed the projections provided herewith.

n/a

The Debtor will not liquidate any equipment or inventory. n/a

The Plan provides for a $373,000 dividend to all unsecured creditors over a period of five (5) 

years, which sum is sufficient to pay all allowed unsecured claims in full. Debtor contends the 

Plan provides for a greater dividend to all creditors than would a liquidation of assets under 

chapter 7.

2 This value reflects a 50% reduction of the receivables booked.

3 This value reflects a 35% reduction in value. 4 This value reflects a 15% reduction in value.

Case 24-30808-sgj11 Doc 74 Filed 06/21/24 Entered 06/21/24 18:46:23 Desc Main

Document Page 45 of 52
EXHIBIT “B”

Set of projections are attached.

Case 24-30808-sgj11 Doc 74 Filed 06/21/24 Entered 06/21/24 18:46:23 Desc Main

Document Page 46 of 52
Monthly

7 8 9 10 11

INCOME

 Gross Income $180,000.00 $180,000.00 $180,000.00 $180,000.00 $180,000.00

TOTAL Income $180,000.00 $180,000.00 $180,000.00 $180,000.00 $180,000.00

EXPENSES

Bank Charges and Fees $300.00 $300.00 $300.00 $300.00 $300.00

Fuel $27,000.00 $27,000.00 $27,000.00 $27,000.00 $27,000.00

Insurance $27,000.00 $27,000.00 $27,000.00 $27,000.00 $27,000.00

Legal and Professional Services $3,000.00 $3,000.00 $3,000.00 $3,000.00 $3,000.00

Maintenance and Repairs $7,000.00 $7,000.00 $7,000.00 $7,000.00 $7,000.00

Contractors (1099) Compensation $45,000.00 $45,000.00 $45,000.00 $45,000.00 $45,000.00

Office Supplies and Software $4,000.00 $4,000.00 $4,000.00 $4,000.00 $4,000.00

Payroll Tax $4,000.00 $4,000.00 $4,000.00 $4,000.00 $4,000.00

Rent & Lease $2,000.00 $2,000.00 $2,000.00 $2,000.00 $2,000.00

Taxes & Licenses $1,500.00 $1,500.00 $1,500.00 $1,500.00 $1,500.00

Tolls $500.00 $500.00 $500.00 $500.00 $500.00

Utilities $2,600.00 $2,600.00 $2,600.00 $2,600.00 $2,600.00

Wages $17,000.00 $17,000.00 $17,000.00 $17,000.00 $17,000.00

TOTAL Expenses $140,900.00 $140,900.00 $140,900.00 $140,900.00 $140,900.00

Net Income $39,100.00 $39,100.00 $39,100.00 $39,100.00 $39,100.00

PLAN

Ally 5710 $733.00 $733.00 $733.00 $733.00 $733.00

Ally 5790 $1,020.00 $1,020.00 $1,020.00 $1,020.00 $1,020.00

Ally 4928 $728.00 $728.00 $728.00 $728.00 $728.00

First Citizens 0727 $1,189.00 $1,189.00 $1,189.00 $1,189.00 $1,189.00

First Citizens 1946 $2,007.00 $2,007.00 $2,007.00 $2,007.00 $2,007.00

First Citizens 0525 $2,308.00 $2,308.00 $2,308.00 $2,308.00 $2,308.00

Beacon $2,687.00 $2,687.00 $2,687.00 $2,687.00 $2,687.00

Hartzendorf $4,445.00 $4,445.00 $4,445.00 $4,445.00 $4,445.00

State Comptroller (Priority) $180.00 $180.00 $180.00 $180.00 $180.00

Fora (Claims 15 and 16) $0.00 $0.00 $0.00 $0.00 $0.00

Forny ISD $204.00 $204.00 $204.00 $204.00 $204.00

IRS (Priority) $133.00 $133.00 $133.00 $133.00 $133.00

Kaufman County $239.00 $239.00 $239.00 $239.00 $239.00

Springer $1,444.00 $1,444.00 $1,444.00 $1,444.00 $1,444.00

McLennan County $134.00 $134.00 $134.00 $134.00 $134.00

Pawnee $1,916.00 $1,916.00 $1,916.00 $1,916.00 $1,916.00

Regions $3,140.00 $3,140.00 $3,140.00 $3,140.00 $3,140.00

Santander $2,042.00 $2,042.00 $2,042.00 $2,042.00 $2,042.00

American $1,540.00 $1,540.00 $1,540.00 $1,540.00 $1,540.00

Velocity $7,500.00 $7,500.00 $7,500.00 $7,500.00 $7,500.00

Wells Fargo $1,921.00 $1,921.00 $1,921.00 $1,921.00 $1,921.00

Quest $1,494.00 $1,494.00 $1,494.00 $1,494.00 $1,494.00

Unsecured Creditors $1,000.00 $1,000.00 $1,000.00 $1,000.00 $1,000.00

Total $38,004.00 $38,004.00 $38,004.00 $38,004.00 $38,004.00

Net Income $1,096.00 $1,096.00 $1,096.00 $1,096.00 $1,096.00

Case 24-30808-sgj11 Doc 74 Filed 06/21/24 Entered 06/21/24 18:46:23 Desc Main

Document Page 47 of 52
Monthly

INCOME

 Gross Income

TOTAL Income

EXPENSES

Bank Charges and Fees

Fuel

Insurance

Legal and Professional Services

Maintenance and Repairs

Contractors (1099) Compensation

Office Supplies and Software

Payroll Tax

Rent & Lease

Taxes & Licenses

Tolls

Utilities

Wages

TOTAL Expenses

Net Income

PLAN

Ally 5710

Ally 5790

Ally 4928

First Citizens 0727

First Citizens 1946

First Citizens 0525

Beacon

Hartzendorf

State Comptroller (Priority)

Fora (Claims 15 and 16)

Forny ISD

IRS (Priority)

Kaufman County

Springer

McLennan County

Pawnee

Regions

Santander

American

Velocity

Wells Fargo

Quest

Unsecured Creditors

Total

Net Income

12 1 2 3 4

$180,000.00 $180,000.00 $180,000.00 $180,000.00 $180,000.00

$180,000.00 $180,000.00 $180,000.00 $180,000.00 $180,000.00

$300.00 $300.00 $300.00 $300.00 $300.00

$27,000.00 $27,000.00 $27,000.00 $27,000.00 $27,000.00

$27,000.00 $27,000.00 $27,000.00 $27,000.00 $27,000.00

$3,000.00 $3,000.00 $3,000.00 $3,000.00 $3,000.00

$7,000.00 $7,000.00 $7,000.00 $7,000.00 $7,000.00

$45,000.00 $45,000.00 $45,000.00 $45,000.00 $45,000.00

$4,000.00 $4,000.00 $4,000.00 $4,000.00 $4,000.00

$4,000.00 $4,000.00 $4,000.00 $4,000.00 $4,000.00

$2,000.00 $2,000.00 $2,000.00 $2,000.00 $2,000.00

$1,500.00 $1,500.00 $1,500.00 $1,500.00 $1,500.00

$500.00 $500.00 $500.00 $500.00 $500.00

$2,600.00 $2,600.00 $2,600.00 $2,600.00 $2,600.00

$17,000.00 $17,000.00 $17,000.00 $17,000.00 $17,000.00

$140,900.00 $140,900.00 $140,900.00 $140,900.00 $140,900.00

$39,100.00 $39,100.00 $39,100.00 $39,100.00 $39,100.00

$733.00 $733.00 $733.00 $733.00 $733.00

$1,020.00 $1,020.00 $1,020.00 $1,020.00 $1,020.00

$728.00 $728.00 $728.00 $728.00 $728.00

$1,189.00 $1,189.00 $1,189.00 $1,189.00 $1,189.00

$2,007.00 $2,007.00 $2,007.00 $2,007.00 $2,007.00

$2,308.00 $2,308.00 $2,308.00 $2,308.00 $2,308.00

$2,687.00 $2,687.00 $2,687.00 $2,687.00 $2,687.00

$4,445.00 $4,445.00 $4,445.00 $4,445.00 $4,445.00

$180.00 $0.00 $0.00 $0.00 $0.00

$0.00 $0.00 $0.00 $0.00 $0.00

$204.00 $204.00 $204.00 $204.00 $204.00

$133.00 $0.00 $0.00 $0.00 $0.00

$239.00 $239.00 $239.00 $239.00 $239.00

$1,444.00 $1,444.00 $1,444.00 $1,444.00 $1,444.00

$134.00 $134.00 $134.00 $134.00 $134.00

$1,916.00 $1,916.00 $1,916.00 $1,916.00 $1,916.00

$3,140.00 $3,140.00 $3,140.00 $3,140.00 $3,140.00

$2,042.00 $2,042.00 $2,042.00 $2,042.00 $2,042.00

$1,540.00 $1,540.00 $1,540.00 $1,540.00 $1,540.00

$7,500.00 $7,500.00 $7,500.00 $7,500.00 $7,500.00

$1,921.00 $1,921.00 $1,921.00 $1,921.00 $1,921.00

$1,494.00 $1,494.00 $1,494.00 $1,494.00 $1,494.00

$1,000.00 $1,000.00 $1,000.00 $1,000.00 $1,000.00

$38,004.00 $37,691.00 $37,691.00 $37,691.00 $37,691.00

$1,096.00 $1,409.00 $1,409.00 $1,409.00 $1,409.00

Case 24-30808-sgj11 Doc 74 Filed 06/21/24 Entered 06/21/24 18:46:23 Desc Main

Document Page 48 of 52
Monthly

INCOME

 Gross Income

TOTAL Income

EXPENSES

Bank Charges and Fees

Fuel

Insurance

Legal and Professional Services

Maintenance and Repairs

Contractors (1099) Compensation

Office Supplies and Software

Payroll Tax

Rent & Lease

Taxes & Licenses

Tolls

Utilities

Wages

TOTAL Expenses

Net Income

PLAN

Ally 5710

Ally 5790

Ally 4928

First Citizens 0727

First Citizens 1946

First Citizens 0525

Beacon

Hartzendorf

State Comptroller (Priority)

Fora (Claims 15 and 16)

Forny ISD

IRS (Priority)

Kaufman County

Springer

McLennan County

Pawnee

Regions

Santander

American

Velocity

Wells Fargo

Quest

Unsecured Creditors

Total

Net Income

5 6 Total

$180,000.00 $180,000.00 $2,160,000.00

$180,000.00 $180,000.00 $2,160,000.00

$300.00 $300.00 $3,600.00

$27,000.00 $27,000.00 $324,000.00

$27,000.00 $27,000.00 $324,000.00

$3,000.00 $3,000.00 $36,000.00

$7,000.00 $7,000.00 $84,000.00

$45,000.00 $45,000.00 $540,000.00

$4,000.00 $4,000.00 $48,000.00

$4,000.00 $4,000.00 $48,000.00

$2,000.00 $2,000.00 $24,000.00

$1,500.00 $1,500.00 $18,000.00

$500.00 $500.00 $6,000.00

$2,600.00 $2,600.00 $31,200.00

$17,000.00 $17,000.00 $204,000.00

$140,900.00 $140,900.00 $1,690,800.00

$39,100.00 $39,100.00 $469,200.00

$733.00 $733.00 $8,796.00

$1,020.00 $1,020.00 $12,240.00

$728.00 $728.00 $8,736.00

$1,189.00 $1,189.00 $14,268.00

$2,007.00 $2,007.00 $24,084.00

$2,308.00 $2,308.00 $27,696.00

$2,687.00 $2,687.00 $32,244.00

$4,445.00 $4,445.00 $53,340.00

$0.00 $0.00 $1,080.00

$0.00 $0.00 $0.00

$204.00 $204.00 $2,448.00

$0.00 $0.00 $798.00

$239.00 $239.00 $2,868.00

$1,444.00 $1,444.00 $17,328.00

$134.00 $134.00 $1,608.00

$1,916.00 $1,916.00 $22,992.00

$3,140.00 $3,140.00 $37,680.00

$2,042.00 $2,042.00 $24,504.00

$1,540.00 $1,540.00 $18,480.00

$7,500.00 $7,500.00 $90,000.00

$1,921.00 $1,921.00 $23,052.00

$1,494.00 $1,494.00 $17,928.00

$1,000.00 $1,000.00 $12,000.00

$37,691.00 $37,691.00 $454,170.00

$1,409.00 $1,409.00 $15,030.00

Case 24-30808-sgj11 Doc 74 Filed 06/21/24 Entered 06/21/24 18:46:23 Desc Main

Document Page 49 of 52
Debtor name One More Recovery LLC

United States Bankruptcy Court for the:

Northern District of Texas

Case number (if known): 24-30808 Chapter 11

2. List all contracts and unexpired leases State the name and mailing address for all other parties with whom the

debtor has an executory contract or unexpired lease

2.1

State what the contract or

lease is for and the nature

of the debtor’s interest

Repossession Services Agreement

State the term remaining

List the contract number of

any government contract

Big Time Recovery

9282 Knox Bridge

Canton, GA 30114

2.2

State what the contract or

lease is for and the nature

of the debtor’s interest

Repossession Services Agreement

State the term remaining

List the contract number of

any government contract

Grand Expectations, LLC

5706 E Mockingbird Lane #115

Dallas, TX 75206

2.3

State what the contract or

lease is for and the nature

of the debtor’s interest

Repossession Services Agreement

State the term remaining

List the contract number of

any government contract

LOSS PREVENTION SERVICES, LLC,

P.O. Box 18483

Natchez, MS 39122

2.4

State what the contract or

lease is for and the nature

of the debtor’s interest

Repossession Services Agreement

State the term remaining

List the contract number of

any government contract

MVConnect

260 E. Helen Rd

Palatine, IL 60067

EXHIBIT C: Executory Contracts and Unexpired Leases

Case 24-30808-sgj11 Doc 74 Filed 06/21/24 Entered 06/21/24 18:46:23 Desc Main

Document Page 50 of 52
Debtor One More Recovery LLC Case number (if known) 24-30808

Name

Additional Page if Debtor Has More Executory Contracts or Unexpired Leases

Copy this page only if more space is needed. Continue numbering the lines sequentially from the previous page.

List all contracts and unexpired leases State the name and mailing address for all other parties with whom the

debtor has an executory contract or unexpired lease

2.5

State what the contract or

lease is for and the nature

of the debtor’s interest

Repossession Services

Agreement

State the term remaining

List the contract number of

any government contract

PAR, Inc.

7835 Woodland Drive, Suite 150

Indianapolis, IN 46278

2.6

State what the contract or

lease is for and the nature

of the debtor’s interest

Repossession Services

Agreement

State the term remaining

List the contract number of

any government contract

PATRICK K. WILLIS COMPANY, INC.

5118 Robert J Mathews Pkwy

El Dorado Hills, CA 95762

2.7

State what the contract or

lease is for and the nature

of the debtor’s interest

Repossession Services

Agreement

State the term remaining

List the contract number of

any government contract

Primeritus Financial Services, Inc.

435 Metroplex Drive

Nashville, TN 37211

2.8

State what the contract or

lease is for and the nature

of the debtor’s interest

Repossession Services

Agreement

State the term remaining

List the contract number of

any government contract

Profound Recovery Solutions, Inc.

11618 Fair Oaks Blvd.

Fair Oaks, CA 95628

2.9

State what the contract or

lease is for and the nature

of the debtor’s interest

Repossession Services

Agreement

State the term remaining

List the contract number of

any government contract

Resolution Management Group, LLC

5601 Corporate Way, 117

34407

2.10

State what the contract or

lease is for and the nature

of the debtor’s interest

Repossession Services

Agreement

State the term remaining

List the contract number of

any government contract

Resolvion, LLC

1150 Lake Hearn Drive, Suite 640

Atlanta, GA 30342

Case 24-30808-sgj11 Doc 74 Filed 06/21/24 Entered 06/21/24 18:46:23 Desc Main

Document Page 51 of 52
Debtor One More Recovery LLC Case number (if known) 24-30808

Name

Additional Page if Debtor Has More Executory Contracts or Unexpired Leases

Copy this page only if more space is needed. Continue numbering the lines sequentially from the previous page.

List all contracts and unexpired leases State the name and mailing address for all other parties with whom the

debtor has an executory contract or unexpired lease

2.11

State what the contract or

lease is for and the nature

of the debtor’s interest

Repossession Services

Agreement

State the term remaining

List the contract number of

any government contract

Secure Collateral Management, LLC

9330 Lyndon B Johnson Fwy, 700

Dallas, TX 75243

Case 24-30808-sgj11 Doc 74 Filed 06/21/24 Entered 06/21/24 18:46:23 Desc Main

Document Page 52 of 52