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-- -` `— SENT BY:Xerox Toleco ler 7020 ; 3-20-96 ; 3:41PM ; 9188745 92 <br /> SENT,(,Y:Xerox Telecapier 7020 q0-98 ; 3:40PM ; 91897457'?-• 818 446 1888;# 2 P 916 446 1896;# 3 <br /> .03/115/86 TUE 16; 1 FAX 916 446 . .I6 M&K 0 006 <br /> 9F96 mE 16:51 FAb 918 446 1696 ME 0005 <br /> 1 THOMAS A. EILLOUGHBY - 137597 E�I I s C. The iRS assarts a secured lien on all the inventory and <br /> DIEDTymcfar <br /> FF, PLANT & , <br /> • a 300 �NOX 3 Suite 1700 a recaiv, in of the Lodi Facility, including ail the cash collateral <br /> Poet Box 30315 <br /> 3 Saar CA. 95813-3034 3 genera ad from the operation of the skilled nursing facility (eCash <br /> Tale (916) 444-3910 <br /> 4 a collet rai10) <br /> 5 AttoJONATHAN E.TEBAR, chapter 11 trustee S D The IR6'® claim is for the De!btoiaee <br /> failure to pay trust <br /> 6 6 fund t xes, in an amount in excess of $3150,000. <br /> 7 7 E In excess of $400,000 in r%Ceivablee is ccllsoted each <br /> 8 UNITED STATES IIPTCY COURT S month t the-Lodi Facility. <br /> 9 EASTERN DISTRICT OF CALIFORNIA 9 F Following the Trustee,$ appointment, the IRs agreed with <br /> 10 10 the T stns that ordinary and reasonable operating expenditures of <br /> In re Case No. 96-22902-B-11 11 the L di Facility, as well as Trustee's Leas and Trustee's <br /> LODIEAST-H STTHCARETHCARE, LLC, dba 12 protan ional fees am approved by the Court, could be paid from Cash <br /> 13 <br /> 13 coilat ral. <br /> G Prior to the film <br /> la Debtor. 14 filing,-the IRS had levied upon the Debtor`s <br /> Tax I.D. jF68-035olle 15 and n inee's bank acounte, in an amount <br /> 15 / 1n aKaess of $100,000. <br /> 16 16 <br /> H. The IRS has previously released the Lunde .it had levied <br /> 17 STIPULATION FOR 06$ of CABS COLLKTZRAL 17 from the Debtor's accounts in order to allow tie continued operation <br /> 18 This stipulation is by and between secured creditor, the 18 of the Lodi Facility. The funds releas�d <br /> y the IRB are hereby <br /> Internal Revenue Service (the "IRS") and the 'Chnptes it Trustee of 19 includ d in <br /> 1g the definition of cash ccl�at rel as used in this <br /> East West Healthcare, LLC (the "Trustee"). The stipulation is made 20 &groom t. <br /> 20 <br /> with reference to the following facts. 21 Now, therefore, the IRS and the ,. ru tee herebya <br /> 21 Orae as <br /> A. East West Healthcare, LLC (lithe Debtor") filed its Chapter 22 !allows: � <br /> 22 <br /> 23 <br /> 11 petition on March 11, 1996. on'March 14, 1996, the Court approved 23 1. The Trustee is authorized <br /> t2 use Cash Collateral for <br /> 154 <br /> the appointment of Mr. Jonathan E. Tamar as the Trustee. 24 the ord nary reasonable and necessary.opsr tin expanses of the Lodi <br /> _ <br /> B. The Debtor leases a 150 bed skilled nursing facility, 23 Facility. <br /> located in Lodi, California (the "Lodi Facility"). 26 2. The Trustee is authorized to Use cash Collateral for <br /> 157 fees and <br /> 27 Trustee s gees and expenses and for th expenses of <br /> 8 ill!/ 11111811 II 28 professional& employed by the Trustee. <br /> . lr II I I I <br /> �a G <br /> .n.rm,. 2r oar-a ®1'�taa'IlOt1 <br /> Cq <br /> H B 9 <br />