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03/18/2003 DAVID P. BART DIRECTOR, BANKRUPTCY AND LITIGATION SERVICES NATIONAL CORPORATE RECOVERY PRACTICE PROFESSIONAL SUMMARY Mr. Bart is Director of Bankruptcy and Litigation Services in American Express Tax & Business Services’ (TBS) National Corporate Rec overy Practice. He has 18 years experience assisting parties in interest and their counsel in bankruptcy and commercial litigation. Assignments have included providing expert consulting and testimony in cases involving business operations, fraudulent conveyance, business valuation, forensic accounting and financial investigative projects. His engagements include matters pending at U.S. Bankruptcy Court, U.S. District Court and State Court. He has provided litigation consulting services to named expert witnesses from Harvard, Dartmouth, Stanford and the University of Chicago. Mr. Bart’s expertise includes financial and economic analysis, investigative accounting, statistical analysis, and business valuation. In addition, his business consulting services have resulted in business and financial restructuring, reduced operating costs, identification of unprofitable business segments, and successful negotiation of credit support with vendors and lenders. Prior to joining TBS, Mr. Bart was a Manager in a national bankruptcy and insolvency consulting firm. Mr. Bart previously served in the Special Services Group-Reorganization and Restructuring Practice of a Big Five accounting and financial services firm. Mr. Bart began his career as an analyst in the Corporate Planning Department of an international commercial insurance brokerage firm, where he specialized in coordination of property and liability insurance programs for financially troubled accounts. PROFESSIONAL EXPERIENCE Assignments representative of Mr. Bart's experience include: World Access, Inc. Served as litigation consultant to expert witnesses for the debtor and creditors’ committee of this $500 million telecommunications company regarding a joint plan of reorganization providing testimony on substantive consolidation, business valuation, cash management, financial results, business operations and other matters. RDM Sports, Group, Inc. Served as a financial advisor to the creditors’ committee and Chapter 11 Trustee of this $350 million manufacturer/distributor/retailer of sports and fitness equipment providing litigation consulting and expert witness services, business valuation services, forensic accounting investigations, testimony regarding allegations against the debtor’s management and other services. Midcom Communications, Inc. Currently serving as a disbursing agent to the creditors’ trust of this $200 million telecommunications company providing claims reconciliation services, forensic accounting investigations, creditor distributions and litigation services regarding preference and avoidance actions against the debtor’s management and other parties. Joy Recovery Technologies Currently serving as financial advisor and expert witness to the trustee of this $15 million scrap and waste technology company providing business valuation services, forensic accounting investigations, and litigation services regarding preference and avoidance actions against insiders and other parties.

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Page 1: DAVID P. BART DIRECTOR, BANKRUPTCY AND · PDF fileNATIONAL CORPORATE RECOVERY PRACTICE PROFESSIONAL SUMMARY ... University of Chicago, MBA, ... Accessories Group dba Amity Leather

03/18/2003

DAVID P. BART

DIRECTOR, BANKRUPTCY AND LITIGATION SERVICES NATIONAL CORPORATE RECOVERY PRACTICE

PROFESSIONAL SUMMARY Mr. Bart is Director of Bankruptcy and Litigation Services in American Express Tax & Business Services’ (TBS) National Corporate Recovery Practice. He has 18 years experience assisting parties in interest and their counsel in bankruptcy and commercial litigation. Assignments have included providing expert consulting and testimony in cases involving business operations, fraudulent conveyance, business valuation, forensic accounting and financial investigative projects. His engagements include matters pending at U.S. Bankruptcy Court, U.S. District Court and State Court. He has provided litigation consulting services to named expert witnesses from Harvard, Dartmouth, Stanford and the University of Chicago. Mr. Bart’s expertise includes financial and economic analysis, investigative accounting, statistical analysis, and business valuation. In addition, his business consulting services have resulted in business and financial restructuring, reduced operating costs, identification of unprofitable business segments, and successful negotiation of credit support with vendors and lenders. Prior to joining TBS, Mr. Bart was a Manager in a national bankruptcy and insolvency consulting firm. Mr. Bart previously served in the Special Services Group-Reorganization and Restructuring Practice of a Big Five accounting and financial services firm. Mr. Bart began his career as an analyst in the Corporate Planning Department of an international commercial insurance brokerage firm, where he specialized in coordination of property and liability insurance programs for financially troubled accounts. PROFESSIONAL EXPERIENCE Assignments representative of Mr. Bart's experience include:

World Access, Inc. Served as litigation consultant to expert witnesses for the debtor and creditors’ committee of this $500

million telecommunications company regarding a joint plan of reorganization providing testimony on substantive consolidation, business valuation, cash management, financial results, business operations and other matters.

RDM Sports, Group, Inc. Served as a financial advisor to the creditors’ committee and Chapter 11 Trustee of this $350 million

manufacturer/distributor/retailer of sports and fitness equipment providing litigation consulting and expert witness services, business valuation services, forensic accounting investigations, testimony regarding allegations against the debtor’s management and other services. Midcom Communications, Inc.

Currently serving as a disbursing agent to the creditors’ trust of this $200 million telecommunications company providing claims reconciliation services, forensic accounting investigations, creditor distributions and litigation services regarding preference and avoidance actions against the debtor’s management and other parties.

Joy Recovery Technologies Currently serving as financial advisor and expert witness to the trustee of this $15 million scrap and waste

technology company providing business valuation services, forensic accounting investigations, and litigation services regarding preference and avoidance actions against insiders and other parties.

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03/18/2003

DAVID P. BART Page Two Real Estate Developments

Served as financial advisor to a secured lender regarding the investigation of financial accounting, expense reimbursement, projected costs of completion and insider compensation regarding five real estate developments involving multiple loans made by the lender to two developers.

Brandess Home Builders Served as financial advisor to the Court appointed Bankruptcy Examiner regarding the investigation of

financial accounting, expense reimbursement, project costs, insider transactions and business viability for this Chicago area real estate developer.

Midwest Video Games, Inc. Served as financial advisor to the creditors’ committee regarding this $20 million video game wholesaler in the investigation of certain transactions and the pursuit of insider preference actions by providing business valuation and forensic accounting services. Flint Area Newspapers Served as financial advisor to the Court Appointed Examiner and testified regarding valuation issues and forensic accounting investigations for this regional newspaper chain. $80 Million Healthcare Non-Profit Assisted the debtor in a corporate turnaround engagement involving operating evaluations, cash flow management, financing negotiations with lenders and bond holders for this regional healthcare provider and non-profit program administrator. EDUCATION

University of Chicago, MBA, Concentrations in Finance and Accounting University of Chicago, BA, Major: Anthropology, Minor: Statistics PROFESSIONAL CERTIFICATIONS AND MEMBERSHIPS

Certified Insolvency and Reorganization Accountant Certified Fraud Examiner American Express Tax & Business Services National Litigation Services Steering Committee – Member American Bankruptcy Institute – Member of several committees Association of Insolvency Accountants - Member Association of Certified Fraud Examiners – Member American Society of Appraisers – Member Illinois CPA Society - Member SPEECHES AND ARTICLES

Mr. Bart has written numerous articles about bankruptcy/insolvency related topics and was a contributor to a book about value based management. He also teaches an annual seminar on bankruptcies, reorganizations and troubled loan workouts. CONTACT INFORMATION: 312-634-4733 Phone 312-634-5520 FAX [email protected] American Express Tax and Business Services Inc. One South Wacker Drive, Suite 800 Chicago, IL 60606

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03/18/2003

DAVID P. BART -- SUPPLEMENT

PUBLICATIONS IN PAST 10 YEARS “Using A Financial Expert In Your Litigation Cases”, David Bart, Lawyer’s Business Watch, Winter 2003. “Creditor’s Ability to Prevent Against Preference Liability”, Scott Peltz, David Bart, and John Dahl, Iowa Chapter Federal Bar Association and Bankruptcy Seminars, Inc. Spring Bankruptcy Workshop, May 10, 2002. “How To Survive Litigation: Class Action Suits and Settlements”, David P. Bart, Fulcrum Information Services, Inc., May 16, 2001. “Accountants As Expert Witnesses In Bankruptcy Cases”, David P. Bart and Scott Peltz, American Bankruptcy Institute Spring Meeting, April 19, 2001. “Ethical Issues In Professional Marketing, Retention and Fees”, David P. Bart and Scott Peltz, American Bankruptcy Institute Spring Meeting, April 27, 2000. “Computers, Preferences and The Search For Efficiency”, Iowa Chapter Federal Bar Association and Bankruptcy Seminars Winter Bankruptcy Workshop, David P. Bart and Scott Peltz, March 9, 2000. “Rethinking The Concept of Success in Bankruptcy and Corporate Recovery”, David P. Bart and Scott Peltz, American Bankruptcy Institute Journal, Vol. XVII No. 4, May 1998. “The Relationship Between The Chapter 11 Trustee And The Creditors’ Committee”, David P. Bart and William H. Grabscheid, Bankruptcy and Insolvency Section of the Commercial Law League of America, April 7, 1995. “The Use of Non-Bankruptcy Alternatives: What Are They and Which Is Appropriate?”, David P. Bart and Robert C. Larry, Published by The Grabscheid Group, Ltd., January 1995. “Book Review: Tax Issues in Bankruptcy: Complete Planning and Practice Guide”, David P. Bart and William H. Grabscheid, Commercial Law Bulletin, Commercial Law League of America, January 1995. “Assignment For The Benefit of Creditors v. Bankruptcy”, David P. Bart, Robert C. Larry and William H. Grabscheid, UCC Bulletin , December 1993. “Non-Legal Professionals Serving The Committee”, David P. Bart, Robert C. Larry and William H. Grabscheid, American Bankruptcy Institute Winter Leadership Conference, December 1993. “Assignment For The Benefit of Creditors v. Bankruptcy”, David P. Bart, Robert C. Larry and William H. Grabscheid, Secured Lender, May 1993.

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03/18/2003

DAVID P. BART -- SUPPLEMENT

TESTIMONY

Case Name

Case No.

Jurisdiction

Testimony

In re Proteva, Inc. 98B19860 U.S. Bankruptcy Court, Northern District of Illinois, Eastern Division

Expert Report.

In re Heick Die Casting, Inc.

01B45708 U.S. Bankruptcy Court, Northern District of Illinois, Eastern Division

Expert Report, Deposition.

In re Gropman, Inc. 98B19860 U.S. Bankruptcy Court, Northern District of Illinois, Eastern Division

Expert Report, Deposition, Trial.

In re Weatherly Hospitality Group, Inc., f/k/a Errant Enterprises, Inc. et al

97B39524 U.S Bankruptcy Court, Northern District of Illinois, Eastern Division

Expert Report, Deposition.

In re Proteva, Inc. 98B19860 U.S. Bankruptcy Court, Northern District of Illinois, Eastern Division

Testimony proffered at Trial for Committee.

In re RDM Sports Group, Inc.

97B12788 U.S Bankruptcy Court, Northern District of Georgia, Newnan Division

Testimony proffered at Trial.

In re Janet and Leo Brandess

96B19474 U.S. Bankruptcy Court, Northern District of Illinois, Eastern Division

Expert Report, no testimony.

In re Englewood Lizzie Acquisition LLC

95B14582 U.S. Bankruptcy Court, Northern District of Illinois, Eastern Division

Expert Report, Trial.

In re Flint Area News, Inc.

92B20192 U.S. Bankruptcy Court, Eastern District of Michigan, Southern Division

Expert Report, Trial.

In re H.C. Prange Company et al

94-25108-JES

U.S. Bankruptcy Court, Eastern District of Wisconsin

Trial.

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03/18/2003

DAVID P. BART -- Supplement

LITIGATION EXPERIENCE U.S. Bankruptcy Court, Eastern District of Missouri, Eastern Division: Litigation consultant for Post Confirmation Plan Administrator regarding fraudulent transfer action under the U.S. Bankruptcy Code for this $1.2 billion international data and information services provider (In re Bridge Information Systems, Inc.). U.S. Bankruptcy Court, Northern District of Illinois, Eastern Division: Expert witness for secured lender regarding feasibility and valuation issues in Plan of Reorganization confirmation hearings for this $20 million regional aluminum die casting business (In re Heick Die Casting, Inc.). Expert report, deposition testimony. U.S. Bankruptcy Court, Northern District of Illinois, Eastern Division: Expert witness for Chapter 7 Trustee as plaintiff in preference and fraudulent transfer action under the U.S. Bankruptcy Code and the Uniform Fraudulent Transfer Act regarding solvency and reasonably equivalent value of this $20 million wholesale computer manufacturing business (In re Proteva, Inc.). Pending. U.S. Bankruptcy Court, District of Colorado: Litigation consultant for named expert witness on behalf of Chapter 7 Trustee regarding business valuation and solvency issues in fraudulent transfer matters involving this $50 million national telecommunications company (In re Greg A. Dickey v. Evans et al a/k/a Convergent Communications). Pending. U.S. Bankruptcy Court, Northern District of Illinois, Eastern Division: Litigation consultant for named expert witness on behalf of secured lender regarding feasibility and valuation issues in Plan of Reorganization confirmation hearings for this $5 million local hotel and restaurant business (In re JBD Allied LLC dba Schaumburg Holiday Inn). Co-authored expert reports, preparation for deposition and trial testimony. U.S. Bankruptcy Court, Northern District of Illinois, Eastern Division: Litigation consultant to Chapter 7 Trustee regarding corporate investigations, solvency analysis and investigations of Directors and Officers liability issues for this $300 million international aluminum processing company (In re McCook Metals Corporation). Pending. U.S. Bankruptcy Court, Northern District of Illinois, Eastern Division: Litigation consultant to Chapter 7 Trustee regarding corporate investigations, solvency analysis and investigations of Directors and Officers liability issues for this $1 billion international boat and engine manufacturing company (In re Outboard Marine Corporation). Pending. U.S. Bankruptcy Court, Northern District of Illinois, Eastern Division: Litigation consultant to named expert witnesses including a professor at the Harvard University Business School on behalf of the Debtor regarding feasibility and valuation issues in Plan of Reorganization Confirmation Hearings for this $500 million international telecommunications company (In re World Access, Inc.). Co-authored expert reports, preparation for deposition and trial testimony. U.S. Bankruptcy Court, Northern District of Illinois, Eastern Division: Expert witness for Chapter 7 Trustee as plaintiff in preference and fraudulent transfer action under the U.S. Bankruptcy Code and the Uniform Fraudulent Transfer Act regarding solvency and reasonably equivalent value of this $12 million wholesale distribution business (In re Gropman, Inc.). Expert report, deposition and trial testimony. U.S Bankruptcy Court, Northern District of Illinois, Eastern Division: Expert witness for defendant in a fraudulent transfer matter under the Uniform Fraudulent Transfer Act regarding solvency and fair value of this $10 million regional restaurant chain (In re Weatherly Hospitality Group, Inc., f/k/a Errant Enterprises, Inc., et al). Expert report, deposition testimony.

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DAVID P. BART -- Supplement

LITIGATION EXPERIENCE – Continued (2)

03/18/2003

U.S Bankruptcy Court, Northern District of Illinois, Eastern Division: Litigation consultant to named expert witness for Liquidating Trustee in preference and fraudulent transfer matter under the U.S. Bankruptcy Code and Uniform Fraudulent Transfer Act regarding solvency and reasonably equivalent value of this $15 million regional scrap and metal recovery business (In re Joy Recovery Technology Corporation). Co-authored expert report, preparation for deposition and trial testimony. U.S Bankruptcy Court, Eastern District of Wisconsin: Litigation consultant to named expert witness for Chapter 7 Trustee in preference and fraudulent transfer matter under the Uniform Fraudulent Transfer Act regarding solvency and reasonably equivalent value of this $90 million national leather goods manufacturer (In re AR Accessories Group dba Amity Leather Goods and Amity Wallet Works). Co-authored expert report. U.S District Court, Northern District of Illinois, Eastern Division: Litigation consultant to named expert witness, a former professor at Stanford University, on behalf or the plaintiff regarding lost profits and consequential damages in a product liability matter for this $350 million national sports equipment manufacturer (In re RDM Sports Group, Inc.). Co-authored expert report, preparation for deposition testimony. U.S. Bankruptcy Court, Northern District of Illinois, Eastern Division: Expert witness for Official Committee of Unsecured Creditors regarding feasibility and best interests tests including substantive consolidation in Plan of Reorganization Confirmation Hearings for of this $20 million wholesale computer manufacturing business (In re Proteva, Inc.). Testimony proffered at trial. U.S Bankruptcy Court, Northern District of Georgia, Newnan Division: Litigation consultant to Official Committee of Unsecured Creditors and named expert witness regarding forensic accounting, financial analysis, corporate investigations, feasibility, DIP financing and asset valuation issues culminating in confirmation hearings on the Plan of Reorganization for this $350 million national sports equipment manufacturer (In re RDM Sports Group, Inc.). Co-authored expert reports, preparation for deposition and trial testimony. U.S Bankruptcy Court, Northern District of Georgia, Newnan Division: Litigation consultant to Chapter 11 Trustee and Post-Confirmation Trustee regarding Director and Officer liability and accounting malpractice matters including lawsuits against former accountants, former corporate counsel and former Directors and Officers for this $350 million national sports equipment manufacturer (In re RDM Sports Group, Inc.). Co-authored consulting reports. Arbitration (New York): Litigation consultant to named expert witness, a professor at Dartmouth University Amos Tuck Graduate School of Business, on behalf of the Post Confirmation Trustee regarding fair value of contract performance in an acquisition by this $300 million international telecommunications company (In re USN Communications, Inc.). Co-authored expert reports, preparation for deposition and trial testimony. U.S. District Court For The State of Colorado: Litigation consultant to named expert witness for Post Confirmation Trustee regarding solvency issues in a fraudulent transfer matter under the Uniform Fraudulent Transfer Act for this $90 million national hotel and restaurant company (In re Integra—A Hotel and Restaurant Company). Financial analysis, deposition and trial preparation. U.S. District Court For The State of Delaware: Litigation consultant to named expert witnesses, including a professor at the Dartmouth University Amos Tuck School of Business, on behalf of the Post Confirmation Trustee regarding preference and fraudulent transfer matters for this $300 million international telecommunications company (In re USN Communications, Inc.). Co-authored expert reports, preparation for deposition and trial testimony.

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DAVID P. BART -- Supplement

LITIGATION EXPERIENCE – Continued (3)

03/18/2003

Arbitration (Oklahoma City): Litigation consultant to named expert witness for plaintiff regarding contract performance under market hog purchasing contracts and commodity pricing agreements involving this international hog processing business (In re Koch Industries as Successor to Purina Mills, Inc. v. Art Sauder et al). Co-authored expert report, deposition and trial preparation. U.S Bankruptcy Court, Northern District of Illinois, Eastern Division: Litigation consultant to Unofficial Committee of Unsecured Creditors regarding forensic accounting, asset valuation and financial analysis involving allegations of insider fraud for this $10 million regional computer technology company (In re Zebra Technology v. Management System Technolgy). Authored expert report. U.S. Bankruptcy Court, Northern District of Illinois, Eastern Division: Served as litigation consultant to the Official Committee of Unsecured Creditors regarding fraudulent transfer actions under the U.S. Bankruptcy Code and Uniform Fraudulent Transfer Act involving financial analysis, forensic accounting, business valuation, solvency and equity analysis of this $20 million video game wholesaler (In re Midwest Video Games, Inc.) Co-authored litigation consulting reports. In re Terrestris. Litigation consultant to secured lender regarding forensic accounting and financial analysis of loan portfolios for three regional real estate developments involving allegations of insider fraud by this Illinois real estate developer. Co-authored litigation consulting reports. In re Century Homes. Litigation consultant to secured lender regarding forensic accounting and financial analysis of loan portfolios for two regional real estate developments involving allegations of insider fraud by this California residential real estate developer. Co-authored litigation consulting reports. U.S. Bankruptcy Court, Northern District of Illinois, Eastern Division: Submitted expert reports as financial advisor to the Bankruptcy Examiner regarding accounting and financial investigations of this Illinois residential real estate developer (In re Janet and Leo Brandess). Expert reports. U.S. Bankruptcy Court, Northern District of Illinois, Eastern Division: Expert witness for the Chapter 7 Trustee as plaintiff in a preference action under the U.S. Bankruptcy Code regarding solvency and equity values of this mid-west regional steel foundry (In re Englewood Lizzie Acquisition LLC). Expert report, trial testimony. Mediation (New York): Litigation consultant to Court appointed mediator regarding fair value of equity in a joint venture involving one of the developers of global positioning technology (In re Eastern Airlines v. ARINC.). Financial consulting and analysis, mediation. U.S. Bankruptcy Court, Eastern District of Michigan, Southern Division: Expert witness for the Bankruptcy Court Examiner regarding asset valuation, the marketing of business assets and confirmation of a § 363 asset sale of this regional newspaper chain (In re Flint Area Newspapers, Inc.). Expert report, trial testimony. U.S. Bankruptcy Court, Eastern District of Michigan, Southern Division: Litigation consultant to Chapter 11 Trustee and named expert regarding forensic accounting, financial analysis, asset valuation and solvency analysis of this $60 million mid-west regional construction company (In re C.J. Rogers, Inc.). Co-authored expert report, preparation for deposition and trial testimony. U.S. Bankruptcy Court, Eastern District of Wisconsin: Financial consultant and expert witness for Committee of Unsecured Creditors regarding DIP financing, confirmation of a Plan of Reorganization, business valuation, substantive consolidation and other matters for this $70 million mid-west regional retail chain (In re H.C. Prange Company et al). Authored Committee reports, trial testimony.

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DAVID P. BART -- Supplement

LITIGATION EXPERIENCE – Continued (4)

03/18/2003

U.S. Bankruptcy Court, Eastern District of Wisconsin: Litigation consultant for secured lender regarding fraudulent transfer matters including solvency, financial analysis, business valuation and other matters for this $1 billion national regional department store chain (In re P.A. Bergner Company). Authored consulting reports. Illinois State Court, Circuit Court of Cook County: Financial consultant for secured lender and Court appointed Receiver regarding business operations, business valuation, liquidation procedures and other matters for this $2 million regional bowling alley and entertainment center (In re Schaumburg Lanes). Various Court reporting. U.S. Bankruptcy Court, Northern District of Illinois, Eastern Division: Litigation consultant for Unsecured Creditors Committee and named expert witness in Chapter 11 Plan of Reorganization confirmation hearings regarding feasibility, financial analysis, solvency and equity values, and equitable subordination claims for this $40 million regional steel processing company (In re Galaxy Steel and Tube et al). Co-authored expert report, preparation for deposition. U.S. Bankruptcy Court, Northern District of Illinois, Eastern Division: Litigation consultant for Unsecured Creditors Committee and named expert witness in Chapter 11 Plan of Reorganization confirmation hearings regarding feasibility, financial analysis, solvency and equity values of this $200 million international bicycle manufacturer (In re Schwinn Bicycle Company). Co-authored expert report, preparation for deposition and trial testimony. Wisconsin State Court, Circuit Court of Outagamie County: Litigation consultant for secured lender and named expert witness regarding business operations and other matters involving this Wisconsin real estate developer (In re Crivello Associates et al). Co-authored expert report, trial preparation. U.S. Bankruptcy Court, Northern District of Illinois, Western Division: Litigation consultant for named expert witness in fraudulent transfer actions under the U.S. Bankruptcy Code and Uniform Fraudulent Transfer Act regarding financial analysis, solvency and equity values of this $50 million machine tool manufacturer for the die casting industry (In re DeVlieg). Co-authored expert report, preparation for deposition testimony. U.S. Bankruptcy Court, Northern District of Illinois, Western Division: Litigation consultant to Chapter 7 Trustee regarding valuation matters in a sale of the business under the U.S. Bankruptcy Code for this $8 million high pressure injection molding company (In re PlasticCrafters: A Division of Galt Crafted Products, Inc.). Co-authored expert report, preparation for deposition testimony. U.S. Bankruptcy Court, Northern District of Illinois, Eastern Division: Litigation consultant for secured lender and named expert witness in Chapter 11 Plan of Reorganization confirmation hearings regarding feasibility, financial analysis, solvency and equity values of this $35 million regional appliance retailing company (In re North Shore Refrigeration). Co-authored expert report, preparation for deposition and trial testimony. In re Susan Solmor et al v. Donald Grauer. Litigation consultant for trustee regarding investment returns and high yie ld interest rates on various trust funds. Co-authored litigation report. U.S. Bankruptcy Court of Arkansas: Litigation consultant for named expert witness on behalf of secured lender in preference actions under the U.S. Bankruptcy Code regarding financial analysis, new value defenses, collateral values and solvency of this national TL trucking company (In re Jones Truck Lines). Co-authored expert report, preparation for deposition testimony. U.S. Bankruptcy Court, Eastern District of Michigan, Southern Division: Litigation consultant providing business viability and operational analysis and business valuation services for this bankrupt Detroit hospital (In re City of Detroit Sisters of Mercy Hospitals). Co-authored litigation consulting reports.

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DAVID P. BART -- Supplement

LITIGATION EXPERIENCE – Continued (5)

03/18/2003

In re Jiffy Lube. Litigation consultant to named expert witness, a professor at the University of Chicago Graduate School of Business, on behalf of the Debtor regarding financial and statistical analysis of estimated lives of franchise agreements involving class action litigation in Florida.

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03/18/2003

DAVID P. BART -- Supplement

ANALYSIS OF HIGH YIELD RETURNS U.S. Bankruptcy Court, Northern District of Illinois, Eastern Division: Expert report, deposition testimony on behalf of secured lender including analysis of high yield debt and high yield equity market returns for this $20 million aluminum die caster (In re Heick Die Casting, Inc.). U.S Bankruptcy Court, Northern District of Illinois, Eastern Division: Co-authored expert report, preparation for deposition and trial testimony on behalf of Post-confirmation Trustee including analysis of high yield debt and equity market returns for this $15 million scrap metal processing center (In re Joy Recovery Technology Corporation). In re Almetal Industries, Inc. Prepared financial analysis on behalf of investors for use in joint venture financing proposals involving high yield equity investment returns for this $150 million metal processing center. In re Susan Solmor et al v. Donald Grauer. Co-authored litigation report including analysis of high yield debt and equity market returns and comparable returns for various trust funds. In re Zearl T. Young. Co-authored consulting reports on behalf of secured lender including analysis of high yield debt and equity market returns for this southwestern regional retail chain.

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03/18/2003

DAVID P. BART -- Supplement

DEBTOR SERVICES EXPERIENCE In re The Wealshire and The Ponds of Wealshire. Financial advisor to Debtor regarding an out-of-court workout for this $25 million regional nursing home and assisted care center specializing in Alzheimer’s Disease including financial and operational analysis and development of a restructuring plan with and lenders. U.S. Bankruptcy Court, Northern District of Illinois, Eastern Division: Litigation consultant to named expert witnesses including a professor at the Harvard University Business School on behalf of the Debtor regarding feasibility and valuation issues in Plan of Reorganization confirmation hearings for this $500 million international telecommunications company (In re World Access, Inc.). In re Lifelink, Inc. Financial advisor to Debtor regarding an out-of-court workout for this $80 million national health and human services organization including financial and operational analysis and development of a restructuring plan including design, negotiation with bondholder and lenders and plan implementation. In re Briskin Manufacturing Company. Financial advisor to the Debtor regarding the restructuring of operations and financial and accounting management of this $80 million die casting business. U.S District Court, Northern District of Illinois, Eastern Division: Financial advisor to Official Committee of Unsecured Creditors including providing numerous wind-down services to the Debtor and Chapter 11 Trustee for this $350 million national sports equipment manufacturer (In re RDM Sports Group, Inc.). In re Aronson Furniture, Inc. Financial advisor to Debtor regarding financial and operational analysis for this $35 million regional furniture retaile r. In re Almetal Industries, Inc. Prepared financial analysis on behalf of investors for use in joint venture financing proposals involving high yield equity investment returns for this $150 million metal processing company. In re Entre PC Solutions, Inc. Prepared financial analysis on behalf of investors for use in financing proposals involving this $25 million computer services company. In re Celotex Inc. Financial advisor to Debtor regarding financial and operational analysis and strategic planning for this $350 million roofing and construction materials company. In re Pulver Genau Inc. Financial advisor to Debtor regarding an out-of-court workout for this national bagel oven manufacturer including financial and operational analysis and development of a restructuring plan including design, negotiation and implementation. U.S. Bankruptcy Court, Northern District of Illinois, Eastern Division: Financial advisor to Official Committee of Unsecured Creditors and subsequent manager of Debtor’s businesses under a Chapter 11 Plan of Reorganization for this $40 million regional steel processing company (In re Galaxy Steel and Tube et al). U.S. Bankruptcy Court, Northern District of Illinois, Eastern Division: Financial advisor for secured lender and subsequent joint advisor to Debtor in Chapter 11 Plan of Reorganization regarding financial management, restructuring of operations and feasibility of this $35 million regional appliance retailing company (In re North Shore Refrigeration). In re Illinois Computer Cable Company. Financial advisor to the Debtor regarding the restructuring of operations and financial and accounting management of this $15 million computer cable and wiring business. In re Harvey Chrysler Plymouth. Financial advisor to the Debtor regarding the restructuring of operations and financial and accounting management of the largest minority owned car dealership in Illinois.

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DAVID P. BART -- Supplement

DEBTOR SERVICES EXPERIENCE – Continued (2)

03/18/2003

In re Herff Steel Fabricating. Served as financial advisors to equity holders regarding operational changes and a financial restructuring for this mid-west regional steel fabricator. In re Matthews Boucher. Financial advisor to the Debtor regarding the restructuring of operations, financial management and refinancing of this outdoor sports, hunting and largest Remington Arms wholesaler in the U.S. In re Movietime Home Video. Financial advisor to the Debtor regarding financial analysis and negotiating a financial restructuring in an out-of-court workout for this local video store chain. In re Milwaukee Concrete. Financial advisor to the Debtor regarding the restructuring of operations and financial management of this mid-west regional outdoor statue and ornament wholesaler. In re Interpane Glass Company, Inc. Financial advisor to the Debtor regarding the restructuring of operations, accounting management, and refinancing of the 3rd largest commercial glass manufacturer in the world. In re Acorn Building Components, Inc. Financial advisor to the Debtor regarding the restructuring of operations for this national metal and screen door manufacturer. In re Peck Foods Corporation. Financial advisor to the Debtor regarding the restructuring of operations, financial management, development of a pre-packaged bankruptcy and refinancing of the 8th largest meat packing business in the U.S. In re Spectrum Glass Company, Inc. Financial advisor to the Debtor regarding the restructuring of operations, financial management, development of a pre-packaged bankruptcy and sale of this U.S. commercial glass manufacturer. In re Whirlpool Finance Company, Inc. Financial advisor to the Debtor regarding the restructuring of financial and credit operations for this national appliance finance company. In re Florida Steel Company. Financial advisor to the Debtor regarding strategic planning and the restructuring of operations in a management buyout of this regional steel company. In re Thomson Newspapers. Financial advisor to Debtor regarding asset purchase price allocation and financial projections in various newspaper acquisitions for this international newspaper conglomerate. In re Shaw Newspapers. Financial advisor to Debtor regarding asset purchase price allocation and financial projections in a newspaper acquisition for this national newspaper chain. In re Paducah Newspapers. Financial advisor to Debtor regarding asset purchase price allocation and financial projections in a newspaper acquisition for this regional newspaper. In re United Educators, Inc. Financial advisor to Debtor regarding asset purchase price allocation and financial projections for this national educational book publisher.

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03/18/2003

DAVID P. BART -- Supplement

CREDITORS’ COMMITTEE EXPERIENCE U.S Bankruptcy Court, Northern District of Illinois, Eastern Division: Accountant and financial advisor to Official Committee of Unsecured Creditors regarding forensic accounting, asset valuation and sale procedures, financial analysis, and structuring and negotiating a Plan of Reorganization for this regional casino development (In re Emerald Casino, Inc.). U.S Bankruptcy Court, Northern District of Ohio: Financial advisor to Official Committee of Unsecured Creditors regarding forensic accounting, asset valuation, financial analysis, and structuring and negotiating a Plan of Reorganization for this national steel producer (In re CSC Steel, Inc.). U.S Bankruptcy Court, Northern District of Illinois, Eastern Division: Accountant and financial advisor to Official Committee of Unsecured Creditors regarding forensic accounting, asset valuation, financial analysis, negotiation of DIP financing, and structuring and negotiating a Plan of Reorganization for this national truck manufacturing company (In re Trailmobile Trailer LLC). U.S Bankruptcy Court, Northern District of Georgia, Newnan Division: Financial advisor to Official Committee of Unsecured Creditors and named expert witness regarding forensic accounting, asset valuation, financial analysis, negotiation of DIP financing, and structuring and negotiating a Plan of Reorganization for this $350 million national sports equipment manufacturer (In re RDM Sports Group, Inc.). U.S. Bankruptcy Court, Northern District of Illinois, Eastern Division: Expert witness for Official Committee of Unsecured Creditors regarding feasibility and best interests tests including substantive consolidation in Plan of Reorganization Confirmation Hearings for of this $20 million wholesale computer manufacturing business (In re Proteva, Inc.). U.S Bankruptcy Court, Northern District of Georgia, Newnan Division: Financial advisor to Official Committee of Unsecured Creditors regarding asset valuation, financial analysis, and dissolution of this regional LTL carrier (In re Diversified Trucking, Inc.). U.S Bankruptcy Court, Eastern District of Wisconsin: Financial advisor and litigation consultant to Official Committee of Unsecured Creditors regarding forensic accounting, asset valuation, financial analysis, and structuring and negotiating a Plan of Reorganization of this $90 million national leather goods manufacturer (In re AR Accessories Group dba Amity Leather Goods and Amity Wallet Works). U.S Bankruptcy Court, Northern District of Illinois, Eastern Division: Financial advisor and litigation consultant to Unofficial Committee of Unsecured Creditors regarding forensic accounting, asset valuation and financial analysis for this regional computer technology company (In re Zebra Technology v. Management System Technolgy). U.S Bankruptcy Court, Northern District of Illinois, Eastern Division: Financial advisor and litigation consultant to Official Committee of Unsecured Creditors regarding forensic accounting, asset valuation, financial analysis, and structuring and negotiating a Plan of Reorganization for this regional nursing home company (In re Tutwiler). U.S. Bankruptcy Court, Northern District of Illinois, Eastern Division: Financial advisor and litigation consultant to the Official Committee of Unsecured Creditors regarding fraudulent transfer actions under the U.S. Bankruptcy Code and Uniform Fraudulent Transfer Act involving financial analysis, forensic accounting, business valuation, solvency and equity analysis of this $20 million video game wholesaler (In re Midwest Video Games, Inc.).

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DAVID P. BART -- Supplement

CREDITORS’ COMMITTEE EXPERIENCE – Continued (2)

03/18/2003

U.S Bankruptcy Court, Eastern District of Wisconsin: Financial advisor and litigation consultant to Official Committee of Unsecured Creditors regarding forensic accounting, asset valuation, compensation analysis, financial analysis, negotiation of DIP financing, and structuring and negotiating a Plan of Reorganization of this $200 million national discount retailer (In re Everything’s A Dollar). U.S. Bankruptcy Court, Eastern District of Wisconsin: Financial advisor and expert witness for Official Committee of Unsecured Creditors regarding operational analysis, business valuation, substantive consolidation, negotiation of DIP financing, structuring and negotiating a Plan of Reorganization, and other matters for this $70 million regional retail chain (In re H.C. Prange Company et al). U.S. Bankruptcy Court, Northern District of Illinois, Eastern Division: Financial advisor to Official Committee of Unsecured Creditors providing forensic accounting, feasibility and financial analysis, solvency and equity valuation, became subsequent manager of Debtor’s businesses under a Chapter 11 Plan of Reorganization successfully obtaining equitable subordination claims, performing asset liquidation, claims analysis and creditor distributions for this $40 million regional steel processing company (In re Galaxy Steel and Tube et al). U.S. Bankruptcy Court, Northern District of Illinois, Eastern Division: Financial advisor to Official Committee of Unsecured Creditors providing forensic accounting and financial analysis, subsequently performing asset liquidation, claims analysis and creditor distributions for this $15 million regional steel processing company (In re Calumet Steel and Tube). U.S. Bankruptcy Court, Northern District of Illinois, Eastern Division: Financial Advisor and litigation consultant for Official Committee of Unsecured Creditors regarding feasibility, financial analysis, business valuation, solvency and equity values, negotiation of DIP financing and negotiation of a Chapter 11 Plan of Reorganization for this $200 million international bicycle manufacturer (In re Schwinn Bicycle Company). U.S. Bankruptcy Court, Northern District of Illinois, Eastern Division: Financial advisor to the Official Committee of Unsecured Creditors providing accounting and financial analysis, business valuation services, negotiation of DIP financing and negotiation of a Plan of Reorganization for this national wholesale distributor of casino gaming equipment and retail electronic and computer media. (In re WICO Corporation).

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03/18/2003

DAVID P. BART -- Supplement

LENDER SERVICES EXPERIENCE U.S. Bankruptcy Court, Northern District of Illinois, Eastern Division: Expert witness for secured lender regarding feasibility and valuation issues in Plan of Reorganization confirmation hearings for this $20 million regional aluminum die casting business (In re Heick Die Casting, Inc.). In re Ace Great Dane. Financial advisor to the secured lender regarding financial analysis and asset verification for this regional custom trucking manufacturer and retailer. In re Terrestris. Financial advisor and litigation consultant to secured lender regarding forensic accounting and financial analysis of loan performance and obligations stemming from three Illinois real estate developments. In re Century Homes. Financial advisor and litigation consultant to secured lender regarding forensic accounting and financial analysis of loan performance and obligations stemming from two California real estate developments. U.S. Bankruptcy Court, Northern District of Illinois, Eastern Division: Financial advisor and litigation consultant to the secured lender regarding financial analysis and business valuation and equity analysis of this $50 million fish processor and wholesaler (In re Chicago Fish House, Inc.). U.S. Bankruptcy Court, Northern District of Illinois, Eastern Division: Financial advisor and litigation consultant to the secured lender regarding financial analysis and business valuation and equity analysis of this $35 million regional appliance retailer (In re North Shore Refrigeration, Inc.). U.S. Bankruptcy Court of Arkansas: Litigation consultant for named expert witness on behalf of secured lender in preference actions under the U.S. Bankruptcy Code regarding financial analysis, new value defenses, collateral values and solvency of this national TL trucking company (In re Jones Truck Lines). Co-authored expert report, preparation for deposition testimony. Illinois State Court, Circuit Court of Cook County: Financial consultant for secured lender and Court appointed Receiver regarding business operations, business valuation, liquidation procedures and other matters for this $2 million regional bowling alley and entertainment center (In re Schaumburg Lanes). Various Court reporting. In re Zearl T. Young. Financial advisor to secured lender including analysis of high yield debt and equity market returns, financial and accounting analys is of operations, and negotiation of an out-of-court restructuring for this southwestern regional retail chain. Wisconsin State Court, Circuit Court of Outagamie County: Litigation consultant for secured lender and named expert witness regarding business operations and other matters involving this Wisconsin real estate developer (In re Crivello Associates et al). Co-authored expert report, trial preparation. In re Maine Energy Recovery Company. Financial advisor to the secured lender regarding cash flow management, operational and financial forecasting, and negotiation of an out-of-court restructuring for this regional energy co-generation facility. In re Doskocil Companies. Financial advisor to the secured lenders regarding cash flow management, financ ial forecasting and negotiation of a plan of reorganization for this national hog producer. In re Pleasant Woods Apartments. Financial advisor to the secured lender regarding cash flow management and financial forecasting in an out-of-court restructuring for this regional apartment real estate development.

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DAVID P. BART -- Supplement

LENDER SERVICES EXPERIENCE – Continued (2)

03/18/2003

In re Interco – Floresheim Shoe Company. Financial Advisor to the secured lender regarding financial analysis, operational analysis and cash flow forecasting for this international shoe manufacturer and retailer. In re Hernando Healthcare. Financial advisor to the secured lender providing viability analysis, cash flow forecasting, and business valuation services for this Tampa Bay regional healthcare complex. In re John Knox Village. Financial advisor to the secured lender in an out-of-court workout providing viability analysis, cash flow forecasting, and business valuation services for this retirement home. In re Wheeling Pittsburgh Steel. Financial consultant to secured lenders providing strategic planning and economic analysis of market demand regarding this integrated steel company’s Chapter 11 bankruptcy.

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03/18/2003

DAVID P. BART -- Supplement

TRUSTEE & INVESTIGATIVE SERVICES EXPERIENCE U.S. Bankruptcy Court, Northern District of Illinois, Eastern Div ision: Accountant and financial advisor to the Liquidating Trustee regarding accounting and financial investigations, financial analysis, liquidation procedures, claims analysis and creditor distributions (In re CDX Corporation). U.S. Bankruptcy Court, Northern District of Illinois, Eastern Division: Post-Confirmation Disbursing Agent for the Liquidating Trustee regarding accounting and financial investigations, financial analysis, liquidation procedures, claims analysis and creditor distributions (In re Proteva). U.S. Bankruptcy Court, Northern District of Illinois, Eastern Division: Accountant and financial advisor to the Chapter 7 Trustee regarding accounting and financial investigations, financial analysis and completion of tax returns for this local retailer (In re Growth Resources). U.S. Bankruptcy Court, Eastern District of Michigan, Southern Division: Financial advisor to the Post Confirmation Trustee regarding forensic accounting, asset valuation, financial analysis, liquidation procedures, claims analysis and creditor distributions for this $200 million national telecommunications company (In re Midcom Communications, Inc.). U.S. Bankruptcy Court, Northern District of Illinois, Eastern Division: Financial advisor to the Chapter 7 Trustee regarding accounting and financial investigations, claims analysis and calculation of creditor distributions of this former law firm (In re Biegel Lasky). In re Metalmaker, Inc. Assignee for the Benefit of Creditors performing asset liquidation procedures, claims reconciliation and creditor distributions for this mid-west steel services dot-com company. U.S. Bankruptcy Court, Northern District of Illinois, Eastern Division: Financial advisor to the Bankruptcy Examiner regarding accounting and financial investigations of this residential real estate developer including management of Debtor’s finances under expanded powers of the Examiner (In re Janet and Leo Brandess). U.S. Bankruptcy Court, Eastern District of Michigan, Southern Division: Expert witness for the Bankruptcy Court Examiner regarding asset valuation, the marketing of business assets and confirmation of a § 363 asset sale of this regional newspaper chain including joint work with the Debtor for its marketing and sale of the business (In re Flint Area Newspapers, Inc.). U.S. Bankruptcy Court, Northern District of Illinois, Eastern Division: Accountant and financial advisor for the Chapter 11 Trustee regarding liquidation of assets, claims reconciliation, and successful prosecution of fraudulent transfer litigation for this mid-west regional aluminum processor (In re Aluminum Distributors, Inc.). U.S. Bankruptcy Court, Eastern District of Michigan, Southern Division: Financial advisor to the Chapter 11 and Chapter 7 Trustee regarding forensic accounting, asset valuation, financial analysis, liquidation procedures for this mid-west regional construction company (In re C.J. Rogers, Inc.). In re CFM Franchising Company. Assignee for the Benefit of Creditors performing asset liquidation procedures, forensic accounting and investigation, claims reconciliation and creditor distributions for this national Convenient Food Mart franchising company.

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DAVID P. BART -- Supplement

TRUSTEE & INVESTIGATIVE SERVICES EXPERIENCE – Continued (2)

03/18/2003

In re VIII South Michigan. Financial advisor to the Chapter 7 Trustee working in conjunction with the Receiver including cash management and financial analysis regarding this Chicago office building bankruptcy. In re Schaumburg Lanes. Receiver performing asset liquidation procedures, forensic accounting and investigation, claims reconciliation and creditor distributions for this $2 million regional bowling and entertainment center. In re The Belmont Hotel. Financial advisor for the Illinois Development Finance Authority regarding forensic accounting and financial analysis of this mixed income real estate development. Numerous investigations and related services conducted in litigation, bankruptcy, trustee and other engagements.

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03/18/2003

DAVID P. BART -- Supplement

STEEL EXPERIENCE U.S. Bankruptcy Court, Northern District of Illinois, Eastern Division: Expert witness for secured lender regarding feasibility and valuation issues in Plan of Reorganization confirmation hearings for this $20 million regional aluminum die casting business (In re Heick Die Casting, Inc.). Expert report, deposition testimony. U.S. Bankruptcy Court, Northern District of Illinois, Eastern Division: Litigation consultant to Chapter 7 Trustee regarding corporate investigations and Directors and Officers liability cases for this $300 million international aluminum processing company (In re McCook Metals Corporation). Pending. U.S Bankruptcy Court, Northern District of Ohio: Financial advisor to Official Committee of Unsecured Creditors regarding forensic accounting, asset valuation, financial analysis, and structuring and negotiating a Plan of Reorganization for this national steel producer (In re CSC Steel, Inc.). In re Metalmaker, Inc. Assignee for the Benefit of Creditors performing asset liquidation procedures, claims reconciliation and creditor distributions for this mid-west steel services dot-com company. U.S Bankruptcy Court, Northern District of Illinois, Eastern Division: Litigation consultant to named expert witness for Liquidating Trustee in preference and fraudulent transfer matter under the U.S. Bankruptcy Code and Uniform Fraudulent Transfer Act regarding solvency and reasonably equivalent value of this $15 million regional scrap and metal recovery business (In re Joy Recovery Technology Corporation). In re Almetal Industries, Inc. Prepared financial analysis on behalf of investors for use in joint venture financing proposals involving high yield equity investment returns for this $150 million metal processing center. U.S. Bankruptcy Court, Northern District of Illinois, Eastern Division: Financial advisor to Official Committee of Unsecured Creditors providing forensic accounting, feasibility and financial analysis, solvency and equity valuation, became subsequent manager of Debtor’s businesses under a Chapter 11 Plan of Reorganization successfully obtaining equitable subordination claims, performing asset liquidation, claims analysis and creditor distributions for this $40 million regional steel processing company (In re Galaxy Steel and Tube et al). U.S. Bankruptcy Court, Northern District of Illinois, Eastern Division: Financial advisor to Official Committee of Unsecured Creditors providing forensic accounting and financial analysis, subsequently performing asset liquidation, claims analysis and creditor distributions for this $15 million regional steel processing company (In re Calumet Steel and Tube). U.S. Bankruptcy Court, Northern District of Illinois, Eastern Division: Expert witness for the Chapter 7 Trustee as plaintiff in a preference action under the U.S. Bankruptcy Code regarding solvency and equity values of this regional steel foundry (In re Englewood Lizzie Acquisition LLC). In re Herff Steel Fabricating. Served as financial advisors to equity holders regarding operational changes and a financial restructuring for this mid-west regional steel fabricator. U.S. Bankruptcy Court, Northern District of Illinois, Eastern Division: Accountant and financial advisor for the Chapter 11 Trustee regarding liquidation of assets, claims reconciliation, and successful prosecution of fraudulent transfer litigation for this mid-west regional aluminum processor (In re Aluminum Distributors, Inc.). In re Florida Steel Company. Financial advisor to the Debtor regarding strategic planning and the restructuring of operations in a management buyout of this regional steel company. In re Wheeling Pittsburgh Steel. Served as financial consultants to secured lenders providing strategic planning and economic analysis of market demand regarding this integrated steel company’s Chapter 11 bankruptcy.

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03/18/2003

DAVID P. BART -- Supplement

RETAIL EXPERIENCE U.S Bankruptcy Court, Northern District of Illinois, Eastern Division: Expert witness for defendant in a fraudulent transfer matter under the Uniform Fraudulent Transfer Act regarding solvency and fair value of this $10 million regional restaurant chain (In re Weatherly Hospitality Group, Inc., f/k/a Errant Enterprises, Inc., et al). Expert report, deposition testimony. U.S. Bankruptcy Court, Northern District of Illinois, Eastern Division: Accountant and financial advisor to the Chapter 7 Trustee regarding accounting and financial investigations, financial analysis and completion of tax returns for this local retailer (In re Growth Resources). In re Ace Great Dane. Financial advisor to the secured lender regarding financial analysis and asset verification for this regional custom trucking manufacturer and retailer. U.S. Bankruptcy Court, Northern District of Illinois, Eastern Division: Served as litigation consultant to the Official Committee of Unsecured Creditors regarding fraudulent transfer actions under the U.S. Bankruptcy Code and Uniform Fraudulent Transfer Act involving financial analysis, forensic accounting, business valuation, solvency and equity analysis of this $20 million video game wholesaler (In re Midwest Video Games, Inc.) In re Aronson Furniture, Inc. Financial advisor to Debtor regarding financial and operational analysis for this $35 million regional furniture retailer. U.S. Bankruptcy Court, Eastern District of Wisconsin: Financial advisor and expert witness for Official Committee of Unsecured Creditors regarding operational analysis, business valuation, substantive consolidation, negotiation of DIP financing, structuring and negotiating a Plan of Reorganization, and other matters for this $70 million regional retail chain (In re H.C. Prange Company et al). U.S. Bankruptcy Court, Eastern District of Wisconsin: Litigation consultant for secured lender regarding fraudulent transfer matters including solvency, financial analysis, business valuation and other matters for this $1 billion national regional department store chain (In re P.A. Bergner Company). Illinois State Court, Circuit Court of Cook County: Financial consultant for secured lender and Court appointed Receiver regarding business operations, business valuation, liquidation procedures and other matters for this $2 million regional bowling alley and entertainment center (In re Schaumburg Lanes). U.S Bankruptcy Court, Eastern District of Wisconsin: Financial advisor and litigation consultant to Official Committee of Unsecured Creditors regarding forensic accounting, asset valuation, compensation analysis, financial analysis, negotiation of DIP financing, and structuring and negotiating a Plan of Reorganization of this $200 million national discount retailer (In re Everything’s A Dollar). In re Zearl T. Young. Co-authored consulting reports on behalf of secured lender including analysis of high yield debt and equity market returns for this southwestern regional retail chain. U.S. Bankruptcy Court, Northern District of Illinois, Eastern Division: Financial advisor for secured lender and subsequent joint advisor to Debtor in Chapter 11 Plan of Reorganization regarding financial management, restructuring of operations and feasibility of this $35 million regional appliance retailing company (In re North Shore Refrigeration). In re Harvey Chrysler Plymouth. Financial advisor to the Debtor regarding the restructuring of operations and financial and accounting management of the largest minority owned car dealership in Illinois.

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DAVID P. BART -- Supplement

RETAIL EXPERIENCE – Continued (2)

03/18/2003

In re Matthews Boucher. Financial advisor to the Debtor regarding the restructuring of operations, financial management and refinancing of this outdoor sports, hunting and largest Remington Arms wholesaler in the U.S. In re Movietime Home Video. Financial advisor to the Debtor regarding financial analysis and negotiating a financial restructuring in an out-of-court workout for this local video store chain. In re Milwaukee Concrete. Financial advisor to the Debtor regarding the restructuring of operations and financial management of this mid-west regional outdoor statue and ornament wholesaler. In re CFM Franchising Company. Assignee for the Benefit of Creditors performing asset liquidation procedures, forensic accounting and investigation, claims reconciliation and creditor distributions for this national Convenient Food Mart franchising company. In re Jiffy Lube. Litigation consultant to named expert witness, a professor at the University of Chicago Graduate School of Business, on behalf of the Debtor regarding financial and statistical analysis of estimated lives of franchise agreements involving class action litigation in Florida. In re Interco – Floresheim Shoe Company. Financial Advisor to the secured lender regarding financial analysis, operational analysis and cash flow forecasting for this international shoe manufacturer and retailer.

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03/18/2003

DAVID P. BART -- Supplement

SUBSTANTIVE CONSOLIDATION EXPERIENCE U.S. Bankruptcy Court, Northern District of Illinois, Eastern Division: Litigation consultant to named expert witnesses including a professor at the Harvard University Business School on behalf of the Debtor and Creditors’ Committee regarding feasibility and valuation issues including substantive consolidation in Plan of Reorganization Conf irmation Hearings for this $500 million international telecommunications company (In re World Access, Inc.). U.S. Bankruptcy Court, Northern District of Illinois, Eastern Division: Expert witness for Official Committee of Unsecured Creditors regarding feasibility and best interests tests including substantive consolidation in Plan of Reorganization Confirmation Hearings for of this $20 million wholesale computer manufacturing business (In re Proteva, Inc.). U.S District Court, Northern District of Illinois, Eastern Division: Financial advisor to Official Committee of Unsecured Creditors including financial and tax analysis regarding substantive consolidation matters in a Plan of Reorganization for this $350 million national sports equipment manufacturer (In re RDM Sports Group, Inc.). U.S Bankruptcy Court, Eastern District of Wisconsin: Financial advisor and litigation consultant to Official Committee of Unsecured Creditors regarding forensic accounting, asset valuation, compensation analysis, financial analysis, negotiation of DIP financing, and structuring and negotiating a Plan of Reorganization including substantive consolidation matters for this $200 million national discount retailer (In re Everything’s A Dollar). U.S. Bankruptcy Court, Eastern District of Wisconsin: Financial consultant and expert witness for Committee of Unsecured Creditors regarding DIP financing, confirmation of a Plan of Reorganization, business valuation, substantive consolidation and other matters for this $70 million mid-west regional retail chain (In re H.C. Prange Company et al). U.S. Bankruptcy Court, Northern District of Illinois, Eastern Division: Financial advisor to Official Committee of Unsecured Creditors providing forensic accounting, feasibility and financial analysis, solvency and equity valuation and financial analysis of substantive consolidation issues; became manager of Debtor’s businesses under a Chapter 11 Plan of Reorganization successfully obtaining equitable subordination claims, performing asset liquidation, claims analysis and creditor distributions for this $40 million regional steel processing company (In re Galaxy Steel and Tube et al). U.S. Bankruptcy Court, Northern District of Illinois, Eastern Division: Financial advisor and litigation consultant for Official Committee of Unsecured Creditors regarding feasibility, financial analysis, business valuation, solvency and equity values, negotiation of DIP financing and negotiation of a Chapter 11 Plan of Reorganization including substantive consolidation of this $200 million international bicycle manufacturer (In re Schwinn Bicycle Company). U.S. Bankruptcy Court, Northern District of Illinois, Eastern Division: Financial advisor for secured lender and subsequent joint advisor to Debtor in Chapter 11 Plan of Reorganization regarding financial management, restructuring of operations, feasibility and substantive consolidation of this $35 million regional appliance retailing company (In re North Shore Refrigeration).