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1 2 3 4 5 6 7 8 9 In re 10 TC GLOBAL, INC., 11 Debtor. 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 CATHERINE CAMPBELL declares as follows: 1.

HONORABLE KAREN A. OVERSTREET HEARING DATE: FRIDAY, DECEMBER 7, 2012 HEARING TIME: 9:30 A.M. LOCATION: SEATTLE, COURTROOM 7206 RESPONSES DUE: FRIDAY, NOVEMBER 30, 2012

UNITED STATES BANKRUPTCY COURT WESTERN DISTRICT OF WASHINGTON

No. 12-20253 DECLARATION OF CATHERINE CAMPBELL IN SUPPORT OF DEBTOR'S MOTION FOR AUTHORITY TO SELL CERTAIN INVENTORY AND EQUIPMENT WITHOUT NEED FOR ADDITIONAL NOTICE AND FOR AUTHORITY TO CONSIGN PIANO FOR SALE NUNC PRO TUNC

I am the Chief Financial Officer of TC Global, Inc. dba Tully’s Coffee (“Debtor”),

debtor-in-possession herein. I have personal knowledge of the facts set forth herein and I am competent to testify to the same. 2. The Debtor recently closed nine of its retail coffee shop locations. Prior to that, the

Debtor had closed ten additional locations. The Debtor is now required to pay $1,100.00 per month for offsite storage to house the equipment and inventory previously at the closed locations for which the Debtor no longer has a need.
B USH S TROUT & K ORNFELD
LAW OFFICES LLP

1977 20121 xj301v06ys

DECLARATION OF CATHERINE CAMPBELL IN SUPPORT OF DEBTOR'S MOTION FOR AUTHORITY TO SELL CERTAIN INVENTORY AND EQUIPMENT WITHOUT NEED FOR ADDITIONAL NOTICE, ETC. - 1

5000 Two Union Square 601 Union Street Seattle, Washington 98101-2373 Telephone (206) 292-2110 Facsimile (206) 292-2104

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3.

The Debtor estimates that the maximum liquidation value of the equipment and

inventory is approximately $140,000. In the past, the Debtor has worked with equipment resellers to sell individual pieces of equipment. Additionally, the Debtor has received inquiries from other coffee shops or individuals that are interested in purchasing individual pieces of equipment and portions of inventory. 4. The Debtor believes that it will obtain the highest value for its equipment and

inventory by selling it itself in multiple small sales to a variety of interested purchasers as opposed to having an auction. 5. The Debtor does not anticipate that a sale to any one purchaser would yield greater

than $25,000 and that the vast majority of sales would be much smaller. 6. The Debtor’s 4th & Union downtown Seattle location featured a baby grand piano.

That location was closed as of October 14, 2012. 7. The Debtor estimates that the piano is worth approximately $3,500 based upon a

consignment quote by Northwest Pianos, LLC (“NWP”), a business that regularly sells and warrantees used pianos. 8. In order to avoid the expense of moving the piano and to facilitate the sale of the item

the Debtor no longer needs, the Debtor entered into a Piano Consignment Agreement (“Agreement”) with NWP on October 12, 2012. A true copy of the Agreement is attached hereto as Exhibit A. 9. It is the Debtor’s business judgment that the Agreement provides the means to recover

the most value for the piano and requests that the Court authorize the Debtor to enter into and perform under the Agreement nunc pro tunc. /// ///
DECLARATION OF CATHERINE CAMPBELL IN SUPPORT OF DEBTOR'S MOTION FOR AUTHORITY TO SELL CERTAIN INVENTORY AND EQUIPMENT WITHOUT NEED FOR ADDITIONAL NOTICE, ETC. - 2

B USH S TROUT & K ORNFELD
LAW OFFICES

LLP

1977 20121 xj301v06ys

5000 Two Union Square 601 Union Street Seattle, Washington 98101-2373 Telephone (206) 292-2110 Facsimile (206) 292-2104

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10.

I declare under penalty of perjury under the laws of the state of Washington that the

foregoing is true and correct. DATED at Seattle, Washington, this 31st day of October, 2012. /s/ Catherine Campbell Catherine Campbell

1977 20121 xj301v06ys

DECLARATION OF CATHERINE CAMPBELL IN SUPPORT OF DEBTOR'S MOTION FOR AUTHORITY TO SELL CERTAIN INVENTORY AND EQUIPMENT WITHOUT NEED FOR ADDITIONAL NOTICE, ETC. - 3

B USH S TROUT & K ORNFELD
LAW OFFICES

LLP

5000 Two Union Square 601 Union Street Seattle, Washington 98101-2373 Telephone (206) 292-2110 Facsimile (206) 292-2104

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EXHIBIT A
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