EXHIBIT 99.1
EXHIBIT D
ESTIMATED RESULTS OF IMPLEMENTATION OF PLAN
PAYMENT FROM PURCHASER 2,475,989 (1)
ESTIMATED COSTS & EXPENSES FOR ORDINARY COURSE
ADMINISTRATIVE CLAIMS REQUIRED TO BE
PAID FROM PURCHASER'S PAYMENT:
Driver & Owner/Operator Pay 1,020,000
Office Payroll on Retained Employees 135,898
Health & Workers' Comp. Insurance 5,913
Employer Taxes on Payroll (est. at 8%) 43,512
Road Service Cost (Fuel, etc.) 43,750
Reported Unpaid Road & Fuel Taxes 33,000
Over the Road Cost (Pallets, etc.) 13,125
Building Rent 15,000
Communications, Utilities, etc. 25,000
Computer Lease 9,500
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Subtotal (1,344,698)
OTHER ADMINISTRATIVE CLAIMS & EXPENSES:
Estimated Professional Fees Over Retainers on
Effective Date 500,000
Equipment Leases 25,500
Employee Health Insurance 250,000
IBM Lease Payments 50,000
Unpaid and Unreported Road & Fuel Taxes 525,000
QualComm Post-Petition Equipment Use 120,000
Open Post-Petition Accounts Payable 667,000
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Subtotal (2,137,500)
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NET BEFORE OTHER CASH ASSETS TO BE LIQUIDATED (1,006,209)
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(1) This amount is subject to adjustment at closing on the Effective
Date. See Article I (A)(54) of the Plan.
OTHER CASH ASSETS TO BE LIQUIDATED
Projected Collections of Accounts Receivable
Over Outstanding Line Balance to Norwest (2) 1,018,000
Rockwell Office lease Deposit (Bank IV) 177,500
Adriatic Insurance Own-Risk Insurance Deposit 96,000
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NET BEFORE OTHER ASSETS TO BE LIQUIDATED 285,291
OTHER ASSETS TO BE LIQUIDATED (ALL ESTIMATED): HIGH LOW
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Indiana Workers' Comp. Bond in Excess of Claims 200,000 100,000
Citation Workers' Comp. Litigation 600,000 240,000
Subrogation Claims 75,000 40,000
Shop Warranty Receivable 16,000 16,000
Bakersfield Property 800,000 200,000
Preference/Avoidance and Other Litigation Unknown Unknown
Claims ------- -------
Subtotal 1,691,000 596,000
ESTIMATED EXPENSES OF LIQUIDATION OF ALL OTHER ASSETS (100,000) (100,000)(3)
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1,591,000 496,000
ESTIMATED NET TO CLASS 19 UNSECURED CREDITORS (LOW) 781,291
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ESTIMATED NET TO CLASS 19 UNSECURED CREDITORS (HIGH) (4) 1,876,291
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(2) See accounts receivable liquidation analysis in Article X(D)(1) of the
Disclosure Statement.
(3) Because liquidation of these assets may involve litigation, the costs
of liquidation could significantly exceed this estimate.
(4) Estimate does not include possible preference/avoidance claim
recoveries. There can be no assurance that any recovery will be obtained on
such claims.