S.M.F. Group - Chapter 11 Case Summary

Business Description

With a mailing address of 810 Seventh Avenue, Suite 615, New York, NY 10019, S.M.F. Group Inc., together with its 21 affiliated debtors and debtors in possession (collectively, the "Fireman Group" or the "Debtors"), operates a portfolio of iconic restaurants in New York City's entertainment and cultural districts, steps from Carnegie Hall and Lincoln Center and in the heart of the Theater District, and in Washington, D.C.

• The Debtors' restaurants are among the City's longest-running and most recognizable dining destinations, having served generations of theatergoers, concertgoers, and visitors.
• Each offers a full-service dining experience, ranging from classic Italian cooking to American grill fare and elevated diner classics, served in spacious, art-filled marquee locations known for generous portions and attentive hospitality.

As of the date of the declaration, the Debtors employ more than 800 individuals across their corporate offices and nine restaurants.

The Debtors' declaration in support of their Chapter 11 petitions and first day relief was submitted by Jordan Meyers, Chief Restructuring Officer of S.M.F. Group Inc. and its affiliated debtors, and a Managing Director at SierraConstellation Partners LLC ("SCP"), an interim management and advisory firm serving middle-market companies. Mr. Meyers has over 17 years of experience providing transformation, fiduciary, restructuring advisory, interim management and litigation support services to distressed companies, and is a Certified Public Accountant and Certified Insolvency and Restructuring Advisor.

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Corporate History

The Debtors were founded by the late Sheldon "Shelly" Fireman, a celebrated New York restaurateur, sculptor, and designer who opened his first restaurant, The Hip Bagel, in Greenwich Village in 1963. In the decades that followed, Mr. Fireman built a collection of large-format restaurants that became fixtures of the City's dining landscape:

• Café Fiorello, opposite Lincoln Center, has operated for more than fifty years.
• Trattoria Dell'Arte, across from Carnegie Hall, has operated for nearly forty years.
• Brooklyn Diner and Redeye Grill (until its closure in July 2026) have each operated for approximately three decades.

Ownership and Management

• Mr. Fireman passed away in October 2025, and his estate retains ownership of all or a majority of each Debtor entity. Unless otherwise shown in the organizational chart attached to the declaration as Exhibit A, all or the majority interest in each of the Debtors is held by the Estate of Sheldon Fireman.
  • The Fireman Group Cafe Concepts, Inc. also holds nominal stakes of 0.15% in Red Eye/Brooklyn Associates, L.P. and 0.11% in Cieli Partners, L.P.
• Benjamin Grossman joined Fireman Hospitality Group as its Chief Strategy Officer in 2017 and was named CEO in 2020.

Restructuring Advisors

• SCP was first retained by the Debtors to provide financial advisory services on or about March 10, 2026, and Mr. Meyers was appointed as CRO to the Debtors on August 9, 2026.
• The Debtors filed their petitions for relief under chapter 11 of the Bankruptcy Code on August 9, 2026 (the "Petition Date"), in the U.S. Bankruptcy Court for the Southern District of New York, where the 22 Debtors' cases are jointly administered under Case No. 26-11893 (SAB).

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Operations Overview

The Debtors operate nine restaurants through the following entities:

• Brasserie 57 LLC ("B57"): operates the restaurants known as Paris Bar / Le Jardin at 120 W. 57th Street, New York, NY.
• Broadway Hospitality Venture, LLC ("Bond 45"): operates Bond 45 at 221 W 46th St, New York, NY 10036.
• Brooklyn Diner USA, L.P. ("Diner 57"): operates Brooklyn Diner at 212 W 57th St, New York, NY 10019.
• Cafe Concepts (Washington DC), LLC ("CCDC"): operates Café Fiorello at 1001 Pennsylvania Ave. NW, Washington, DC 20004.
• Cieli Partners, L.P. ("Cieli"): operates Trattoria Dell'Arte at 900 7th Ave, New York, NY 10106.
• Ebbets Field Venture, LLC ("Deli 57"): operates USA Brooklyn Delicatessen at 200 W 57th St, New York, NY 10019.
• Fiorello's Roman Cafe, Inc. ("Fiorello"): operates Café Fiorello at 1900 Broadway, New York, NY 10023.
• Italian Cafe Concepts, LLC ("Paradiso"): operates Café Paradiso at 144 W 65th St, New York, NY 10023.
• The Finer Diner, LLC ("Diner 43"): operates Brooklyn Diner at 155 W 43rd St, New York, NY 10036.

In July 2026, the Debtors closed the Redeye Grill restaurant, which was operated by Red Eye Grill, L.P. ("Redeye") at 890 7th Ave, New York, NY 10019, and a USA Brooklyn Delicatessen, which was operated by Ebbets Field Venture II, LLC ("Deli 43") and is a separate location from the USA Brooklyn Delicatessen at 200 W 57th Street operated by Deli 57, which remains open. The declaration does not identify the address of the closed delicatessen.

• Pursuant to Local Rule 1007-2(a)(9), Schedule 3 to the declaration provides a summary of the premises owned, leased, or held under other arrangement from which the Debtors operate their business, which also includes the Debtors' corporate office at 810 Seventh Ave, 6th Floor, New York, NY, and a warehouse at 525 Tiffany Street, Bronx, NY 10474.

Payment Processing

In the ordinary course of business, the Debtors' restaurants accept credit and charge cards as payment from patrons, and substantially all of the Debtors' revenues are generated through card transactions.

• Those transactions are processed by American Express Travel Related Services Company, Inc. ("Amex TRS"), Toast, Inc. ("Toast"), and Stripe, Inc. and Stripe Payments Company (together, "Stripe" and, collectively with Amex TRS and Toast, the "Processors"); Toast also provides the restaurants' point-of-sale platform.
• The applicable Debtors are party to merchant or processing agreements with the Processors under which each Processor is obligated to settle and remit the proceeds of card transactions, net of contractually agreed fees and any properly reserved chargebacks, to the applicable Debtor's designated account within the settlement periods provided under the applicable agreements.
  • Per the CRO, Toast performs some or all of its processing functions through Worldpay, LLC or other third parties, and, within Stripe, Stripe Payments Company receives, holds, and settles merchant funds while Stripe, Inc. provides the associated technology services; regardless of the entity or account through which the funds flow, the withheld amounts remain owed to the applicable Debtors.

Management

• Mr. Grossman is responsible for overseeing all aspects of the Fireman Hospitality Group's business, including business development and expansion, executive functions and restaurant operations. He sets and continuously adapts and develops company-wide strategic planning and business development while overseeing all executive functions as well as key personnel who in turn manage the various units.

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Prepetition Obligations

Per Schedule 1 to the declaration, which lists the holders of the five largest secured claims against the Debtors on a consolidated basis (excluding claims of insiders), the listed secured claims total approximately $9,978,290.42, consisting of the BankUnited Facility ($2,762,347.42), the FHGRF LLC secured note ($6,137,136), SBA EIDL loans ($1,043,720), and equipment leases with Leaf Capital/Vend Leasing ($35,087). The schedule does not reflect the security interests that the Debtors' merchant cash advance lenders purport to hold, which the Debtors dispute as described below.

• The Debtors do not presently anticipate disputing the claims listed on Schedule 1, but reserve all rights to assert that any such debt or claim is disputed and to challenge its priority, nature, amount, or status.

BankUnited Facility

• S.M.F. Group Inc. and certain other Debtors are obligors under that certain Loan and Security Agreement dated as of March 11, 2016 (as amended from time to time, and together with all related documents, the "BankUnited Facility") with BankUnited, N.A. ("BankUnited").
  • As of the Petition Date, total indebtedness under the BankUnited Facility was approximately $2,762,347.42.
  • The indebtedness is secured by a first-priority lien on substantially all assets of the applicable obligors, including Bond 45, Diner 43, Diner 57 and Redeye.

SBA Economic Injury Disaster Loans

• Certain Debtors are obligated to the Small Business Administration ("SBA") for Economic Injury Disaster Loans ("EIDL"), which generally have 1-2% interest rates on a 30-year term.
  • Cieli is obligated on an EIDL loan for approximately $125,000, secured by a lien on substantially all of its assets, and Fiorello is obligated on another EIDL loan for approximately $125,000, also secured by a lien on substantially all of its assets.
  • Diner 57, Bond 45 and Redeye are obligated to the SBA for EIDL loans of $125,000, $125,000 and $416,667, respectively, though the Debtors believe that these obligations are not subject to valid and perfected liens on any assets.
  • The individual EIDL loans described in the declaration total approximately $916,667, while Schedule 1 lists the SBA's secured claim at $1,043,720.

Prepetition Note

• In March 2026, the Debtors and FHGRF LLC ("FHGRF", and in its capacity as prepetition lender, the "Prepetition Note Lender") entered into that certain Secured Demand Promissory Note, dated March 17, 2026 (as amended and restated from time to time, the "Prepetition Note"), which obligations are secured by substantially all assets of the Debtors.
  • As of the Petition Date, the balance outstanding on the Prepetition Note is not less than $6,137,136.60, of which at least $2,378,334.60 was advanced as emergency bridge funding after the Debtors' payment processors essentially ceased remitting all payments at the end of July 2026.
  • Per the CRO, the members of FHGRF are current minority and non-controlling investors in certain of the Debtors' restaurants or members or friends of the Fireman family, and Benjamin Grossman, CEO of the Debtors, holds a 35.8% equity interest in FHGRF. Mr. Grossman's interest is non-controlling, is subject to dilution without his consent, and is subject to senior distribution rights of other members.

Merchant Cash Advances

• Certain Debtors are party to a number of merchant cash advance ("MCA") loans. As of March 2026, more than 30 MCAs across 11 lenders were outstanding, with aggregate outstanding obligations of not less than $5.5 million.
• The Debtors believe that each MCA is a criminally usurious and unenforceable loan under applicable nonbankruptcy law and is subject to recharacterization and/or subordination under bankruptcy law. The Debtors also have avoidance action claims and other claims, including civil RICO claims, against some or all such lenders.
  • While the MCA lenders may purport to have security interests in some or all of the Debtors' assets, the Debtors believe that such interests are invalid because the underlying obligations are unenforceable, were not validly granted under the applicable contracts, were not properly perfected, or are otherwise subject to avoidance.
• Since March 2026, the Debtors have negotiated resolutions with several MCA lenders. The Debtors believe the applicable settlement agreements constitute executory contracts and intend to use the bankruptcy process to evaluate such agreements for assumption or rejection as appropriate.

Unsecured Family and Friends Borrowings

• The Debtors began obtaining unsecured borrowings from family and friends in 2025 to bridge critical liquidity gaps. These borrowings are obligations of The Fireman Group Cafe Concepts, Inc. ("CCI") with an original principal amount of $4,500,000.
  • No interest or other payments have been made by the Debtors on account of such borrowings.

Other Unsecured Claims

• With respect to Local Rule 1007-2(a)(4), the declaration incorporates by reference Official Form 204 attached to the Debtors' petitions, which lists the holders of the Debtors' 50 largest unsecured claims on a consolidated basis (excluding claims of insiders).
• Per the Debtors' unaudited consolidated balance sheet as of December 2025, total liabilities were approximately $39.08 million against total assets of approximately $26.1 million, including accounts payable of approximately $11.09 million, intercompany payables of approximately $13.39 million, loans payable of approximately $7.54 million, accrued expenses of approximately $2.8 million, landlord payables of approximately $2.36 million, sales tax payable of approximately $1.4 million, and banquet deposits of approximately $506,000.
  • Of the approximately $26.1 million of total assets, approximately $13.69 million consists of intercompany receivables, with net fixed assets of approximately $8.35 million, receivables of approximately $1.41 million, prepaid expenses of approximately $963,000, cash of approximately $926,000, inventory of approximately $560,000, and other assets of approximately $194,000.
  • Total owners' equity was a deficit of approximately $12.99 million, comprising general partner capital of approximately $2.22 million, limited partner capital of approximately $5.9 million, and accumulated deficit of approximately $21.1 million.

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Events Leading to Bankruptcy

Pandemic Disruption and a Slow Recovery

The Debtors entered the COVID-19 pandemic with substantial debt resulting from construction cost overruns at various locations and losses from a fire at one of their restaurants. The government-mandated shutdowns and the collapse of Broadway, tourism, and Midtown office traffic were catastrophic.

• Given the Debtors' close ties to the City's theaters, concert halls, and visitor economy, recovery was painfully slow, and the Debtors' traffic ultimately did not return to pre-pandemic levels until the fourth quarter of 2025.
• To survive during the pandemic and its aftermath, the Debtors turned to loans under the Paycheck Protection Program and thereafter to the EIDL program, and fell into arrears with certain landlords.

The MCA Spiral

As depressed traffic and revenues continued, in the spring of 2024 the Debtors began obtaining MCA loans to bridge their liquidity gaps. Traffic and revenues still did not recover, and what began as stopgap financing compounded.

• As MCA advances came due against still-recovering revenues, the Debtors were compelled to obtain still more advances on onerous terms, with fixed remittances consuming an ever-growing share of cash receipts, generally with joint obligations across substantially all of the Debtors' entities.
• The burden was aggravated by the structure of these arrangements: the funders claim a percentage of gross receipts, without deduction for the sales taxes the Debtors collect for taxing authorities or the tips collected for employees. Their remittances thus drew upon cash never owned by the Debtors, deepening the crunch and further straining operations.
• In addition to the MCA loans, in 2025 the Debtors began borrowing on an unsecured basis from certain investors, members and friends of the Fireman family or the current CEO. To preserve cash for payroll and essential operations, the Debtors also fell substantially behind on sales tax obligations beginning in October 2025 and started to stretch their vendors beyond stated terms.

Out-of-Court Efforts and MCA Litigation

By March 2026, the Debtors' financial burdens had become unsustainable. The Debtors ceased payments to their MCA lenders and resumed payments of sales taxes, engaged SCP as financial advisor, retained restructuring counsel, and pursued out-of-court resolutions with their creditors.

• These efforts resulted in consensual resolutions with certain lenders and other creditors. However, other MCA lenders declined to engage constructively and instead commenced litigation and aggressive collection activities against the Debtors.
• The Debtors are presently defendants and, where appropriate, counter-claimants in pending actions or proceedings including Apollo Funding Co. v. Brasserie 57 LLC, et al. (N.Y. Sup. Ct., Clinton Cnty.); EBF Holdings, LLC d/b/a Everest Business Funding v. Fiorello's Roman Cafe, Inc. (N.Y. Sup. Ct., N.Y. Cnty.); Capybara Capital, LLC v. Red Eye Grill L.P. (Fla. 15th Cir. Ct.); Fiorello's Roman Cafe, Inc. et al. v. Forward Financing LLC (N.Y. Sup. Ct.), in which the Debtors are the named plaintiffs; the arbitrations captioned Forward Financing LLC v. Italian Cafe Concepts, LLC, et al. (Resolute Systems LLC) and Webfund LLC v. Broadway Hospitality Venture, LLC, et al. (New Era ADR); and four actions brought by Samson MCA LLC in New York Supreme Court, Erie County, against 57th Street Hospitality Partners, LLC, Brasserie 57 LLC, Brooklyn Diner USA, L.P., and Cieli Partners, L.P., and their respective co-defendants.
  • The Debtors have also commenced litigation to void an MCA in Ebbets Field Venture, LLC v. ODK Capital, LLC d/b/a OnDeck.
  • These matters are generally in preliminary stages, and the Debtors intend to resolve them or the underlying claims in the bankruptcy process as appropriate.
  • Other than the MCA-related actions and proceedings described above and the withholding of receipts by the Debtors' payment processors, the Debtors do not believe that there are any material actions or proceedings, pending or threatened, in which a judgment against them or a seizure of their property is imminent.

Processor Withholding and the Liquidity Crisis

Matters reached a crisis in the days preceding the Petition Date. In response to payment redirect notices (the "Redirect Notices") issued by certain MCA lenders, purporting to direct that amounts otherwise payable to the Debtors be paid to such lenders instead, the Processors began withholding substantially all amounts owing to the Debtors.

• Amex TRS has been withholding such amounts since late April 2026, and Toast withheld such amounts intermittently over the same period. The Debtors had been experiencing withholdings with varying degrees of severity since April and had been able to adjust.
• Since the end of July, however, the holds have been essentially total, with each Processor ceasing remittances and withholding substantially all amounts owing to the applicable Debtors. The Debtors did not consent, prepetition or postpetition, to the withholding or diversion of their card transaction proceeds, and no court order has authorized any such withholding or diversion.
• As of the Petition Date, Amex TRS was withholding not less than $3,302,178, Toast was withholding not less than $2,562,910.00, and Stripe was withholding not less than $101,885, in each case owed to one or more of the Debtors, for an aggregate of not less than $5.96 million (such amounts, together with all amounts withheld on account of postpetition card transactions, the "Withheld Amounts"). These figures are based on the CRO's review of information compiled under his supervision from the Processors' settlement and account records.
  • In addition to Amex TRS, Toast and Stripe, certain other counterparties of the Debtors have also withheld amounts; the Debtors seek to resolve such matters without litigation but reserve all of their rights with respect thereto.
• Since the withholding became essentially total at the end of July 2026, the Debtors have received essentially no revenue for more than a week and, as of the Petition Date, had less than $100,000 of available cash in the aggregate. Absent the immediate release of the Withheld Amounts and the resumption of timely ordinary-course settlement and remittance, the Debtors will be unable to fund payroll for their more than 800 employees, remit sales taxes and employee tips, pay rent and vendors, or otherwise continue operating, and, per the CRO, these Chapter 11 Cases will fail at the outset.

Chapter 11 Filing and Turnover Adversary Proceeding

Faced with the imminent inability to continue operating, the Debtors commenced these Chapter 11 Cases on August 9, 2026 to stabilize operations and restore access to their revenues. With the protection of the Court, the Debtors seek to continue the process they started prepetition of improving cash flow, streamlining operations, adjusting to the closure of unprofitable restaurants, and pursuing a value-maximizing restructuring for the benefit of all stakeholders.

• Promptly following the commencement of the cases, the Debtors, through counsel, sent each Processor written notice of the commencement of these cases and of the automatic stay, together with a demand for the turnover of the Withheld Amounts and for continued ordinary-course settlement and remittance of the proceeds of postpetition card transactions. Despite such notice and demand, each Processor has failed to turn over the Withheld Amounts and continues to withhold amounts arising from the Debtors' postpetition operations.
  • Per the CRO, no Processor has paid any of the Withheld Amounts to any MCA lender or other third party; rather, each Processor appears to be holding the funds pending a court order or other resolution of the competing demands upon it.
• Certain of the Debtors, as plaintiffs, have commenced an adversary proceeding against the Processors asserting claims for turnover under section 542 of the Bankruptcy Code, declaratory relief, and injunctive relief, and have contemporaneously filed a motion (the "TRO Motion") seeking entry of an order compelling the Processors to turn over the Withheld Amounts, requiring timely ordinary-course settlement and remittance of the proceeds of postpetition card transactions, and restraining the Processors from transferring any such funds to any party other than the applicable Debtors.
  • According to the Debtors, the requested relief preserves the rights of all parties: any valid liens, claims, or interests in the Withheld Amounts would attach to the turned-over funds unimpaired, compliance would discharge each Processor to the extent of the amounts paid, and the Processors will continue to earn their ordinary-course processing fees.

DIP Financing

The Debtors commenced these cases with less than $100,000 of cash on hand and require new funding to ensure sufficient working capital to operate their businesses, preserve and maximize the value of their estates, administer their estates, and pursue a sale of their assets or a plan resolving these cases. Liquidity needs include payments to employees, third-party vendors, landlords, utilities, taxing authorities, and insurance companies, among others.

• Under the CRO's oversight, SCP has worked with the Debtors to prepare a budget for operating and other administrative expenditures during the next months of these cases (the "DIP Budget"), which the Debtors are negotiating with FHGRF to finalize and file as part of the upcoming motion (the "DIP Motion") to approve the proposed postpetition financing facility (the "DIP Facility").
  • As described therein, the Debtors require approximately $2.3 million of new funding during the interim period, and additional funding upon entry of the final order approving the DIP Motion, so that the Debtors can operate their businesses and commence a sale process or seek to confirm a plan. Per the CRO, the budget is fair, reasonable, and appropriate under the circumstances.
• The DIP Facility is a senior secured superpriority revolving facility from FHGRF LLC (in such capacity, the "DIP Lender"). Upon entry of the interim order (the "Interim Order"), availability under the DIP Facility will be $1,500,000, subject to the terms and conditions of the DIP credit agreement, against the approximately $2.3 million of new funding the DIP Budget reflects is required during the interim period; upon entry of the final order (the "Final Order"), an additional revolving facility may be made available.
  • Proceeds are intended solely to fund the Debtors' ordinary-course operating expenses in accordance with the DIP Budget and the prosecution of these Chapter 11 Cases, as well as the payment of costs and expenses associated with the cases, including the reasonable fees, costs, expenses and disbursements of estate professionals and other bankruptcy-related costs as allowed by the Court.
  • To secure the obligations, the DIP Lender will be granted an allowed superpriority administrative expense claim and first-priority security interests in and liens on the DIP Collateral (other than collateral subject to Permitted Liens), together with junior liens on the collateral that is subject to Permitted Liens.
  • The DIP Facility contemplates a 2:1 creeping roll-up of prepetition obligations owed to the DIP Lender: upon entry of the Interim Order, for every $1 of new money actually drawn, $2 of obligations under the Prepetition Note would be rolled up into obligations under the DIP Facility, with remaining Prepetition Note obligations being rolled up only upon entry of the Final Order.
    • Per the CRO, the roll-up is appropriate and warranted because the DIP Lender's funding under the Prepetition Note was provided when there was little or no alternative financing available and preserved value for the benefit of all stakeholders, and its funding in the period immediately prior to the Petition Date, when the Debtors had essentially no cash inflows, was advanced in contemplation of this filing and saved the Debtors and other creditors from catastrophic consequences.
• The Debtors maintain that the DIP Facility is necessary notwithstanding the relief requested in the TRO Motion. Even assuming the prompt and full release of the Withheld Amounts, the DIP Budget reflects that projected disbursements during the budget period — including payroll and related obligations, rent, sales and other taxes, vendor payments, and the costs of administering these cases — exceed the Withheld Amounts, and the timing and amount of any recovery depend on the outcome of the turnover adversary proceeding and are not assured, with portions of any recovered funds potentially subject to asserted liens or claims that remain to be resolved by the Court.
• On behalf of the Debtors, the CRO approached BankUnited to explore its interest in providing postpetition financing, but BankUnited was unwilling to do so. In the CRO's opinion, third-party lenders would not be willing to fund into the Debtors' situation on a junior basis and further outreach would not have been productive; ultimately, the proposal from FHGRF was the only available option.
  • Per the CRO, the Debtors are not able to obtain unsecured credit or secured credit on more favorable terms and conditions than those provided in the proposed DIP Facility, and the DIP Facility is the product of good faith, arm's-length, vigorous negotiation among the Debtors and FHGRF and their respective counsel and advisors. It was negotiated on behalf of the Debtors by the CRO, together with the Debtors' counsel and advisors, and Mr. Grossman recused himself from the negotiation and approval of the DIP Facility on behalf of the Debtors.
  • Without access to additional funding and the continued use of cash collateral as contemplated under the DIP Facility, the Debtors would suffer immediate and irreparable harm and would be forced to pivot to a liquidation.

First Day Relief

The First Day Motions request authority to, among other things, enter into the DIP Facility, honor workforce-related compensation and benefits obligations, pay claims of certain critical vendors, suppliers, and taxing authorities, continue to honor certain customer programs, and continue the Debtors' cash management system and other operations in the ordinary course of business. The Debtors have also moved for joint administration of the Chapter 11 Cases, authority to file a consolidated list of their 50 largest unsecured creditors and to redact personal identifying information, an extension of time to file their schedules and statement of financial affairs, relief with respect to utility providers and insurance policies, and an order confirming the statutory protections of the Bankruptcy Code. The Debtors request authority, but not direction, to incur indebtedness, pay amounts, or satisfy obligations with respect to the relief requested.

• The Debtors' first omnibus rejection motion (the "Rejection Motion") requests authority to reject certain real property leases or executory contracts and abandon any personal property remaining at such premises, with such rejection and abandonment effective as of the Petition Date.
  • Each lease is for corporate office space determined to be burdensome or a restaurant determined to be underperforming or unprofitable. For each of the leases, the Debtors ceased operations, vacated the premises, and gave notice of surrender to the applicable landlord and provided keys or codes, as applicable, prior to the Petition Date.
  • The Debtors have determined that the costs of the leases outweigh any marginal benefits that could possibly be achieved from assignments or subleases, that the executory contracts set forth therein are burdensome to the estate, and that any remaining personal property is of inconsequential value or that the cost of removing and storing such property for future use, marketing, or sale exceeds its value to the estates.
• The Debtors have also applied for the appointment of Epiq Corporate Restructuring, LLC as claims and noticing agent.
• Pursuant to Local Rule 1007-2(b), Schedules 5 and 6 to the declaration provide the Debtors' estimated payroll and their estimated cash receipts, disbursements, net cash gain or loss, and accruing unpaid obligations and receivables for the 30-day period following the Petition Date. Estimated weekly payroll is approximately $515,000 for hourly employees, approximately $174,808 for non-officer salaried employees, and approximately $7,692 for the CEO.