IN THE CHANCERY COURT OF TENNESSEE FOR THE TWENTIETH JUDICIAL DISTRICT IN DAVIDSON COUNTY

Case No.18-958-I

HH COLLECTIONS, LLC,

Plaintiff,

v.

HEALTHCARE HOLDINGS, LLC,
CELEBRITY HEALTHCARE MANAGEMENT, LLC,
INJURY TREATMENT CENTERS OF TEXAS, LLC,
TEXAS MDDX, LLC,
PRIME GLOBAL ENTERPRISES, LLC,
UNITED JOINT AND SPINE INSTITUTE, LLC, and
INJURY INSTITUTE OF TEXAS, LLC,

Defendants.

NOTICE OF AUCTION FOR THE SALE OF ASSETS

PLEASE TAKE NOTICE that on January 7, 2019, the Chancery Court of Tennessee for the Twentieth Judicial District in Davidson County (the “Court”) entered an order styled “Order (I) Authorizing and Approving Bidding Procedures for the Sale of Certain Collateral, (II) Authorizing the Sale of Certain Collateral, (III) Approving Initial Bid for Purchase of Collateral, (IV) Scheduling an Auction, (V) Scheduling a Hearing and Objection Deadlines with Respect to the Sale of Collateral, (VI) Approving the Form and Manner of Notice Thereof, and (VII) Granting Related Relief” (the “Sale Procedures Order”) approving Bidding Procedures for the sale of approximately $46.6 million in face value of accounts receivable owed to one or more of the Defendants and which were derived from the provision of medical related services to injured individuals and the records associated with the treatments provided and which are or may be necessary to collect said accounts receivable (collectively, the “Accounts Receivable”) as more fully described in the motion styled “Motion for Entry of an Order (I) Authorizing and Approving Bidding Procedures for the Sale of Certain Collateral, (II) Authorizing the Sale of Certain Collateral, (III) Approving Initial Bid for Purchase of Collateral, (IV) Scheduling an Auction, (V) Scheduling a Hearing and Objection Deadlines with Respect to the Sale of Collateral, (VI) Approving the Form and Manner of Notice Thereof, and (VII) Granting Related Relief” (the “Sale Motion”) filed in the Court on December 7, 2018.

Copies of the Sale Procedures Order, the Bidding Procedures, or other documents related thereto are available upon request to R. Campbell Hillyer by calling (901) 680-7326.

 PLEASE TAKE FURTHER NOTICE that the Plaintiff intends to conduct the Auction,

at which it will consider proposals submitted pursuant to the Bidding Procedures as set forth in the Sale Procedures Order, on March 1, 2019 at 9:00 a.m. (prevailing Central Time) at the offices of Butler Snow LLP, 150 3rd Avenue South, Suite 1600, Nashville, TN 37201.

PLEASE TAKE FURTHER NOTICE that the Bid Deadline is February 22, 2019, at 5:00 p.m. (prevailing Central Time), and that any person or entity who wishes to participate in the Auction must comply with the participation requirements, bid requirements, and other requirements set forth in the Bidding Procedures.

PLEASE TAKE FURTHER NOTICE that the Plaintiff reserves the right to modify the Bidding Procedures, in its reasonable business judgment in accordance with the Bidding Procedures.

DATED: January 16, 2019

 

Butler Snow LLP

/s/ R. Campbell Hillyer

6075 Poplar Avenue, Suite 500

Memphis, TN 38119

(901) 680-7326

Attorneys for HH Collections, LLC