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Repayment of the Administrative Expenses Loan shall be provided for in the plan of <br />reorganization as an allowed administrative expense claim under 11 U.S.C. § 503(b). <br />The Administrative Expense Loan is funded to the Debtors through twenty percent (20 %) <br />of the net proceeds collected by the Lenders on certain promissory notes that are presently due <br />and payable to Lenders. See Supporting Declaration, Ex. C § 1.8. On or about February 20, <br />2015, the Lenders funded $33,361.46 of the Administrative Expenses Loan, which was wired to <br />the trust account for the Debtors' counsel, Snell & Wilmer, L.L.P. Counsel for Debtors have <br />transferred $20,000 of these funds to the Debtors' bank account, and are retaining the remaining <br />$13,361.46 in the trust account for expenses associated with mailing the notice of these <br />bankruptcy cases to Federal Resource Corporation's approximately 18,000 shareholders. <br />B. Debtors' Ongoing Expenses <br />The Debtors have prepared the attached Budget, in which the Debtors project their <br />ongoing post- petition operational expense needs through June 2015. These expenses include, <br />among other things: (i) storage and office rent, (ii) internet and phone bills, (iii) payroll and <br />FICA tax, and (iv) postage and printer toner expenses. Payment of such expenses are necessary <br />to keep the Debtors operational pending the confirmation of the Debtors' plan of reorganization. <br />M. RELIEF REQUESTED <br />Through this Motion, the Debtors request that the Court authorize the Debtors to use up <br />to $20,000 of their cash on hand to pay their ongoing operational expenses summarized in the <br />Budget, with the Debtors to exercise their discretion to determine how best to allocate the funds <br />to pay the estate's administrative expenses, exclusive of legal fees and related expenses. <br />IV. LEGAL ANALYSIS <br />Section 363 governs the Debtors use, sale, and lease of roe of the estate. This <br />g property rtY <br />section "is designed to allow a trustee (or a debtor in possession) the flexibility to engage in <br />ordinary transactions without unnecessary creditor and bankruptcy court oversight, while <br />21086535 3 <br />