Alexi C Matousek and Sarah B Matousek

Findings of Fact 1403 8^thStreet Marysville, WA 98270 P 425.212.4800 || F 425.212.4802

Neeleman Law

Group

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Jennifer L. Neeleman, WSBA #37374 Thomas D. Neeleman, WSBA #33980

NEELEMAN LAW GROUP, P.C.

1403 8^thStreet

Marysville, WA 98270 Telephone: (425) 212-4800 Fax: (425) 212-4802 Email: jennifer@neelemanlaw.com Attorneys for Debtors

UNITED STATES BANKRUPTCY COURT

FOR THE EASTERN DISTRICT OF WASHINGTON

In re:

ALEXI & SARAH MATOUSEK

Debtor.

CHAPTER 11

CASE NO. 25-1369

FINDINGS OF FACT AND CONCLUSIONS

OF LAW REGARDING CONFIRMATION

OF DEBTORS' 2^NDAMENDED CHAPTER

11 SUBCHAPTER V PLAN OF

REORGANIZATION

THIS MATTER came before the Honorable Fredrick P. Corbit on October 15, 2025 at 2:00 pm for confirmation of Debtors' 2^ndAmended Chapter 11 Subchapter V Plan of Reorganization filed on October 6, 2025 [ECF No. 44] (the "Plan"). Neeleman Law Group, P.C. appeared as counsel for the Debtors. Other appearances are as noted in the record. The Court having reviewed the Debtors' Plan, the Declaration of Alexi & Sarah Matousek, and other pleadings filed in the case, having heard the arguments of counsel, makes the following

FINDINGS OF FACT AND CONCLUSIONS OF LAW:

1) Debtors filed this Chapter 11 Subchapter V proceeding on August 1, 2025 [ECF No. 1].

So Ordered. Dated: October 16th, 2025

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2) Debtors filed a 2^ndAmended Plan of Reorganization on October 6, 2025 [ECF No. 44].

2) The Plan contains a brief history of the business operations of the Debtors, a liquidation analysis, and projections with respect to the Debtors' ability to make Plan payments. As such, the Plan complies with 11 U.S.C. §1190.

3) As set forth more fully below, the requirements under 11 U.S.C. §1129(a) are met.

4) The Plan Complies with Bankruptcy Code §1129(a)(1) as the Plan satisfies the requirements of 11 U.S.C. §§1122 and 1123. Article III of the Plan designates six (6) separate Classes of Claims and Interests as required by the Bankruptcy Code §1123(a)(1). Article V of the Plan designates the classes of claims which are not impaired by the Plan in accordance with

11 U.S.C. 1123(a)(2). The treatment of each Claim or Interest within a Class is either (i) the same as treatment of each other Claim or Interested in such class or (ii) otherwise consistent with the legal rights of such claimant in accordance with 11 U.S.C. §1123(a)(4). The Plan provides adequate means for its implementation as described in detail in Articles V, VI, VII , and XI by providing for, among other things (i) a method for funding payments to be made on account of allowed Claims; (ii) provision for the distribution of property under the Plan, (iii) resolution of Disputed Claims and (iv) a method for distribution of payments to allowed claims. Accordingly, the provision for implementation of the Plan satisfies 11 U.S.C. §1123(a)(5).

The Plan provides for the payment to creditors under the Plan from a combination of future business income and regular employment income in accordance with 11 U.S.C. §1123(a)(8).

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5) The Plan Proponent Complies with Bankruptcy Code §1129(a)(2). The Court has not issued an order making 11 U.S.C. §1125 applicable and therefore no disclosure statement was prepared in connection with the Plan. The initial plan and subsequent amended plans contain information regarding the historical information regarding the Debtor's business and disclosure regarding the Debtors assets as of the Petition Date. On September 10, 2025, the Debtor sent via first class US mail, the 1^stAmended Plan with Exhibits, Order Setting Confirmation Hearing and Related Deadlines, and Ballot were mailed to all creditors and parties of interest as set forth on the proof of service filed on September 10, 2025 [ECF No. 33].

6) The Plan is Proposed in Good Faith Pursuant to Bankruptcy Code §1129(a)(3). The Plan is structured and proposed in a manner that effectuates the objectives and purposes of the Bankruptcy Code. The Plan contains no provisions that are contrary to state or other laws nor is there any indication that the Debtors lack the ability to consummate the Plan.

7) The Plan Complies with Bankruptcy Code §1129(a)(4). The Plan allows for payment of administrative expenses of the kind specified in 11 U.S.C. §507(a)(1), which includes compensation awarded by the Court to professional persons. The amount has been estimated in the Plan and any payment to be made by the Debtors for services or costs and expenses in connection with the will be approved by Court prior to payments being made.

8) 11 U.S.C. § 1129(a)(5) is inapplicable in this case as no individuals are proposed to serve, after confirmation of the Plan, as a director, officer, or voting trustee of the Debtors, participate in a joint plan with the Debtors, or be a successor to the Debtors under the plan.

9) 11 U.S.C. § 1129(a)(6) in inapplicable in this case as no such regulatory approval is required.

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10) The Plan Complies with Bankruptcy Code §1129(a)(7). A hypothetical liquidation analysis in Chapter 7 has been filed and attached to the Plan as Exhibit D. Under the Plan, each individual holder of a claim or interest who has not accepted the plan will receive or retain property having a present value of not less than what such holder would receive if the property were liquidated under the Chapter 7.

11) The Plan Complies with Bankruptcy Code §§1129(a)(8). Classes 1 through 5 are unimpaired and not entitled to vote for or against the Plan. Class 6 is entitled to vote for or against the Plan. With respect to Class 6 claims, three acceptance votes were received from American Express and two rejection votes were received from Brad Shain as successor to MBI, LLC and Merchants Bank of Indiana. After the 2^ndAmended Plan was filed, the rejection votes were amended to acceptance votes. 100% of the votes were in favor of the Plan.

12) The Plan Complies with Bankruptcy Code §1129(a)(9). The Plan provides for administrative claims against the Debtor to be paid in full as of the Effective Date. The Plan provides for priority claims under 11 U.S.C. §507(a)(8) to be paid during the term of the Plan, not ending 5 years after the date of the order for relief.

13) The Plan Complies with Bankruptcy Code §1129(a)(10). Impaired Class 6 has voted to accept the Plan.

14) The Plan Complies with Bankruptcy Code §1129(a)(11). The Plan shall be funded by regular income of the Debtors. Payments under the plan will be feasible such that confirmation of the Plan is not likely to be followed by the need for liquidation other than that provided in the Plan.

15) The Plan Complies with Bankruptcy Code §1129(a)(12). Debtors paid the Chapter 11 filing fee upon filing and owe no other court fees or fees to the US Trustee.