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Exhibit A, which includes post - petition storage and office rent, telephone and internet bills, and <br />payroll.1 The cash on hand is not subject to a security interests and therefore does not constitute <br />"cash collateral" under 11 U.S.C. § 363(a). To the extent that these expenses are ordinary <br />course, the Debtors maintain that no order of the Court is necessary. Nevertheless, in an <br />abundance of caution, the Debtors submit this Motion to the extent that any of these expenses <br />may be deemed to be outside the ordinary course and to provide notice to the Court, their <br />creditors, and parties in interest of these proposed payments. <br />MEMORANDUM OF POINTS AND AUTHORITIES <br />I. JURISDICTION <br />The Court has jurisdiction over this matter under 28 U.S.C. §§ 157 and 1334, and this is a <br />core proceeding under § 28 U.S.C. § 157(b)(2)(A). Venue of the Motion is proper before this <br />Court under 28 U.S.C. §§ 1408 and 1409. The statutory predicate for the relief requested herein <br />is 11 U.S.C. § 363 and Federal Rule of Bankruptcy Procedure 4001. <br />H. RELEVANT FACTUAL BACKGROUND <br />A. Administrative Expense Loan <br />Prior to December 29, 2014, the Petition Date, certain entities ( "Lenders ") agreed to lend <br />the Debtors up to $500,000 ("Administrative Expenses Loan ") exclusively for payment of <br />administrative and operational expenses of the Debtors associated with their bankruptcy cases, <br />including legal fees, wages, benefits, taxes, U.S. Trustee fees, license fees and the like.2 <br />1 As the Budget is merely a projection of expenses, the Debtors request that they be permitted to <br />exceed the amounts identified in the Budget by fifteen percent (15 %) without seeking further order of the <br />Court. <br />2 A copy of the loan agreement and note are attached collectively as Exhibit "C" to the Declaration <br />of David Leta in support of the Application for Order Authorizing the Employment and Retention of <br />Snell & Wilmer L.L.P. as Counsel for the Debtor ( "Supporting Declaration "). Federal Resources <br />Corporation Dkt. No. 7, Ex. C; Camp Bird Colorado Dkt. No. 8, Ex. C. <br />21086535 2 <br />