in the united states bankruptcy court - AHRMA

in the united states bankruptcy court - AHRMA

Dated: 06/28/07 IN THE UNITED STATES BANKRUPTCY COURT FOR THE MIDDLE DISTRICT OF TENNESSEE NASHVILLE DIVISION IN RE: AMERICAN HISTORIC RACING MOTORC...

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Dated: 06/28/07

IN THE UNITED STATES BANKRUPTCY COURT FOR THE MIDDLE DISTRICT OF TENNESSEE NASHVILLE DIVISION

IN RE: AMERICAN HISTORIC RACING MOTORCYCLE ASSOCIATION, LTD., Debtor.

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BK No. 06-06626-MH3-11

AGREED ORDER REGARDING CLAIMS OF TEAM OBSOLETE LTD.; TEAM OBSOLETE PRODUCTS LTD.; TEAM OBSOLETE PROMOTIONS, INC.; ROBERT T. IANNUCCI; JIM REDMAN; RICK VESCO AS EXECUTOR OF ESTATE OF DON VESCO; DAVE ROPER; LON MCCROSKEY, M.D; ERIK GREEN; AND JON KAIN AND REGARDING CLAIMS, IF ANY, OF THE DEBTOR AGAINST TEAM OBSOLETE LTD.; TEAM OBSOLETE PRODUCTS LTD.; TEAM OBSOLETE PROMOTIONS, INC.; ROBERT T. IANNUCCI; JIM REDMAN; RICK VESCO AS EXECUTOR OF ESTATE OF DON VESCO; DAVE ROPER; LON MCCROSKEY, M.D; ERIK GREEN; AND JON KAIN It appearing to the Court based upon the signatures of counsel for the Debtor and Team Obsolete Ltd.; Team Obsolete Products Ltd.; Team Obsolete Promotions Inc.; Robert T. Iannucci, Jim Redman, Rick Vesco as Executor of the Estate of Don Vesco; Dave Roper; Lon McCroskey, M.D.; Erik Green and John Kain below, that the parties have resolved certain issues between them, it is, ORDERED as follows: 1.

Team Obsolete Ltd.; Team Obsolete Products Ltd.; Team Obsolete Promotions

Inc.; Robert T. Iannucci, Jim Redman, Rick Vesco as Executor of the Estate of Don Vesco; Dave Roper; Lon McCroskey, M.D.; Erik Green and John Kain agree to not pursue or assert any claims against the Debtor in any forum, venue, or jurisdiction and their claims shall not be allowed under 11 U.S.C. §502 of the Bankruptcy Code. 2.

Team Obsolete Ltd.; Team Obsolete Products Ltd.; Team Obsolete Promotions

Inc.; Robert T. Iannucci, Jim Redman, Rick Vesco as Executor of the Estate of Don Vesco; Dave Roper; Lon McCroskey, M.D.; Erik Green and John Kain acknowledge that their prepetiton \\Bms2003svr\Users\WCLIENT\Chapter 11\AHRMA\Agreed Order TO Claims.doc

claims shall be discharged in a confirmed plan of reorganization which provides for such discharge. 3.

Team Obsolete Ltd.; Team Obsolete Products Ltd.; Team Obsolete Promotions

Inc.; Robert T. Iannucci, Jim Redman, Rick Vesco as Executor of the Estate of Don Vesco; Dave Roper; Lon McCroskey, M.D.; Erik Green and John Kain agree that they will not object to any provision in the Debtor’s plan of reorganization to the extent (and only to the extent) that such provision relates to the discharge of their prepetition claims. The above-referenced parties shall retain the right to object to any provisions in the Debtor’s plan of reorganization, but only to the extent that any such plan provision relates to matters other than the discharge of their claims and as to which they have standing to raise such objections. 4.

The Debtor agrees not to pursue or assert any claim, if any, for attorney fees and

costs against Team Obsolete Ltd.; Team Obsolete Products Ltd.; Team Obsolete Promotions Inc.; Robert T. Iannucci, Jim Redman, Rick Vesco as Executor of the Estate of Don Vesco; Dave Roper; Lon McCroskey, M.D.; Erik Green and John Kain in any forum, venue, or jurisdiction. This Order was signed and entered electronically as indicated at the top of the first page.

Submitted for Entry:

/s/ Henry E. Hildebrand Henry E. Hildebrand, III ([email protected]) Lassiter, Tidwell, Davis, Keller & Hogan, PLLC 150 Fourth Avenue, North, Suite 1850 Nashville, TN 37219 615-259-9344 – Telephone 615-687-3275 – Facsimile Attorneys for Robert Iannucci, et al.

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/s/ Samuel K. Crocker Samuel K. Crocker ([email protected]) Timothy G. Niarhos ([email protected]) CROCKER & NIARHOS Suite 2720, Renaissance Tower 611 Commerce Street Nashville, TN 37203 615-726-3322 – Telephone 615-726-6330 – Facsimile Attorneys for Debtor

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This Order has Been electronically signed. The Judge's signature and Court's seal appear at the top of the first page. United States Bankruptcy Court.