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    United States Bankruptcy Court District of Nevada

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    Chapter 11 Dockets
    This document is a declaration in support of a motion to pay salary to James M. Rhodes, who is involved in bankruptcy proceedings for The Rhodes Companies and related entities. It describes that in 2006, when Pinnacle Grading was performing work in Kingman, Arizona, many employees lived in California and needed housing in Kingman. Since there was limited rental property available, James Rhodes personally purchased three houses in Kingman to provide affordable housing for the employees. The declaration aims to show Rhodes' role in addressing a business need, as the motion requests authorization to pay his salary during the bankruptcy proceedings.

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    United States Bankruptcy Court District of Nevada

    Uploaded by

    Chapter 11 Dockets
    21 views3 pages
    This document is a declaration in support of a motion to pay salary to James M. Rhodes, who is involved in bankruptcy proceedings for The Rhodes Companies and related entities. It describes that in 2006, when Pinnacle Grading was performing work in Kingman, Arizona, many employees lived in California and needed housing in Kingman. Since there was limited rental property available, James Rhodes personally purchased three houses in Kingman to provide affordable housing for the employees. The declaration aims to show Rhodes' role in addressing a business need, as the motion requests authorization to pay his salary during the bankruptcy proceedings.

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    This document is a declaration in support of a motion to pay salary to James M. Rhodes, who is involved in bankruptcy proceedings for The Rhodes Companies and related entities. It describes that in 2006, when Pinnacle Grading was performing work in Kingman, Arizona, many employees lived in California and needed housing in Kingman. Since there was limited rental property available, James Rhodes personally purchased three houses in Kingman to provide affordable housing for the employees. The declaration aims to show Rhodes' role in addressing a business need, as the motion requests authorization to pay his salary during the bankruptcy proceedings.

    Copyright:

    Attribution Non-Commercial (BY-NC)
    Download as PDF, TXT or read online from Scribd
    Download as pdf or txt
    21 views3 pages

    United States Bankruptcy Court District of Nevada

    Uploaded by

    Chapter 11 Dockets
    This document is a declaration in support of a motion to pay salary to James M. Rhodes, who is involved in bankruptcy proceedings for The Rhodes Companies and related entities. It describes that in 2006, when Pinnacle Grading was performing work in Kingman, Arizona, many employees lived in California and needed housing in Kingman. Since there was limited rental property available, James Rhodes personally purchased three houses in Kingman to provide affordable housing for the employees. The declaration aims to show Rhodes' role in addressing a business need, as the motion requests authorization to pay his salary during the bankruptcy proceedings.

    Copyright:

    Attribution Non-Commercial (BY-NC)
    Download as PDF, TXT or read online from Scribd
    Download as pdf or txt
    of 3

    Case 09-14814-lbr

    Doc 139

    Entered 05/07/09 10:27:31

    Page 1 of 3 E-File: May 6, 2009

    1 2 2 3 3 4 4 5 5 6 6 7 7 8 8 9 9 10 10 11 11 12 12 13 13 14 14 15 15 16 16 17 17 18 18 19 19 20 20 21 21 22 22 23 23 24 24 25 25 26 26 27 27 28 28

    James I. Stang, Esq. (CA Bar No. 94435) Shirley S. Cho, Esq. (CA Bar No. 192616) Werner Disse, Esq. (CA Bar No. 143458) PACHULSKI STANG ZIEHL & JONES LLP 10100 Santa Monica Blvd., 11th Floor Los Angeles, California 90067-4100 Telephone: 310/277-6910 Facsimile: 310/201-0760 Email: [email protected] [email protected] [email protected] Zachariah Larson, Esq. (NV Bar No. 7787) LARSON & STEPHENS 810 S. Casino Center Blvd., Ste. 104 Las Vegas, NV 89101 Telephone: 702/382.1170 Facsimile: 702/382.1169 Email: [email protected] [Proposed] Attorneys for Debtors and Debtors in Possession

    LARSON & STEPHENS 810 S. Casino Center Blvd., Suite 104 Las Vegas, Nevada 89101 Tel: (702) 382-1170 Fax: (702) 382-1169

    UNITED STATES BANKRUPTCY COURT DISTRICT OF NEVADA In re: THE RHODES COMPANIES, LLC, aka Rhodes Homes, et al.,1 Debtors. Affects: All Debtors Affects the following Debtor(s) Hearing Date: May 15, 2009 Hearing Time: 1:30 p.m. Courtroom 1 Case No.: BK-S-09-14814-LBR (Jointly Administered) Chapter 11

    The Debtors in these cases, along with their case numbers are: Heritage Land Company, LLC (Case No. 0914778); The Rhodes Companies, LLC (Case No. 09-14814); Tribes Holdings, LLC (Case No. 09-14817); Apache Framing, LLC (Case No. 09-14818); Geronimo Plumbing LLC (Case No. 09-14820); Gung-Ho Concrete LLC (Case No. 09-14822); Bravo, Inc. (Case No. 09-14825); Elkhorn Partners, A Nevada Limited Partnership (Case No. 0914828); Six Feathers Holdings, LLC (Case No. 09-14833); Elkhorn Investments, Inc. (Case No. 09-14837); Jarupa, LLC (Case No. 09-14839); Rhodes Realty, Inc. (Case No. 09-14841); C & J Holdings, Inc. (Case No. 09-14843); Rhodes Ranch General Partnership (Case No. 09-14844); Rhodes Design and Development Corporation (Case No. 09-14846); Parcel 20, LLC (Case No. 09-14848); Tuscany Acquisitions IV, LLC (Case No. 09-14849); Tuscany Acquisitions III, LLC (Case No. 09-14850); Tuscany Acquisitions II, LLC (Case No. 09-14852); Tuscany Acquisitions, LLC (Case No. 09-14853); Rhodes Ranch Golf Country Club, LLC (Case No. 09-14854); Overflow, LP (Case No. 09-14856); Wallboard, LP (Case No. 09-14858); Jackknife, LP (Case No. 09-14860); Batcave, LP (Case No. 09-14861); Chalkline, LP (Case No. 09-14862); Glynda, LP (Case No. 09-14865); Tick, LP (Case No. 09-14866); Rhodes Arizona Properties, LLC (Case No. 09-14868); Rhodes Homes Arizona, L.L.C. (Case No. 0914882); Tuscany Golf Country Club, LLC (Case No. 09-14884); and Pinnacle Grading, LLC (Case No. 09-14887).

    73203-001\DOCS_LA:201826.4

    Case 09-14814-lbr

    Doc 139

    Entered 05/07/09 10:27:31

    Page 2 of 3

    1 2 2 3 3 4 4 5 5 6 6 7 7 8 8 9 9 10 10 11 11 12 12 13 13 14 14 15 15 16 16 17 17 18 18 19 19 20 20 21 21 22 22 23 23 24 24 25 25 26 26 27 27 28 28

    DECLARATION OF PAUL DAVID HUYGENS IN SUPPORT OF SUPPLEMENTAL STATEMENT RE MOTION FOR AUTHORIZATION TO PAY SALARY TO JAMES M. RHODES I, Paul David Huygens, declare as follows: 1. I am a Principal of Province Real Estate Advisors LLP (Province),

    which is acting as work-out consultant to the Debtors. The facts set forth in this Declaration are personally known to me and, if called as a witness, I could and would testify thereto. 2. Province provides real estate advisory services, investments, portfolio

    workouts and asset management for real estate companies located primarily in Southern Nevada. 3. Prior to founding Province, I was the Debtors chief financial officer for

    three years from 2004 through 2007. I was responsible for all areas of finance, accounting and treasury, including cash management, sourcing and closing debt transactions. I also worked extensively with managing equity partner relationships and oversaw the areas of sales, marketing, escrow, financial analysis and golf course and trade subsidiary performance. 4. This declaration is submitted in support of the Debtors Supplemental

    LARSON & STEPHENS 810 S. Casino Center Blvd., Suite 104 Las Vegas, Nevada 89101 Tel: (702) 382-1170 Fax: (702) 382-1169

    Statement Re Motion For Authorization To Pay Salary To James M. Rhodes (the Motion), which is being submitted concurrently herewith. 5. In 2006, Pinnacle Grading, LLC (Pinnacle) was (and still is)

    headquartered in Kingman, a small town in Arizona, and was performing extensive grading and excavation work. Many of Pinnacles employees (the Employees) lived in, and commuted from, California and were unwilling to obtain a second home in Kingman. Furthermore,

    Kingman had a small rental community and there was insufficient rental property to house the Employees. Additional housing was needed for the Employees, but there was no provision in the credit agreements with the secured lenders for Pinnacle to purchase or build rental property. 6. In order to solve the Employees housing problem, in late 2006 James M.

    Rhodes purchased three houses (the Houses) in Kingman in order to be able to provide affordable and convenient housing for the Employees. Mr. Rhodes obtained 30-year mortgages

    73203-001\DOCS_LA:201826.4

    Case 09-14814-lbr

    Doc 139

    Entered 05/07/09 10:27:31

    Page 3 of 3

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