Ownership Interests and Actions for Sale

Sale of Equity Interests and Actions, which includes:
Equity Interests:

1. The Seller’s 50% membership interest in First Chicago Financial, LLC (“FCF”), including any alleged individual interests of the Seller in Huebner Ambulatory Surgical Center, LLC;
2. The Seller’s 50% Membership Interest in Voltaire Asset Managers II, LLC (“Voltaire”), including any alleged individual interests of the Seller in Tresha MOB, LLC;
3. The Seller’s interests, if any, in Legitimation LLC

Actions:

1. Palomar, LLC, including its predecessors in interest, assigns, affiliates, members, officers, employees, attorneys, and representatives.
2. Palomar Boerne, LLC, including its predecessors in interest, assigns, affiliates, members, officers, employees, attorneys, and representatives.
3. Palomar II, LLC, including its predecessors in interest, assigns, affiliates, members, officers, employees, attorneys, and representatives.
4. Huebner Ambulatory Surgery Center, LLC, including its predecessors in interest, assigns, affiliates, members, officers, employees, attorneys, and representatives.
5. Voltaire Asset Managers II, LLC, including its predecessors in interest, assigns, affiliates, members, officers, employees, attorneys, and representatives.
6. Foundation Bariatric Hospital of San Antonio, LLC, d/b/a Foundation Surgical Hospital of San Antonio (“Foundation”) including its predecessors in interest, assigns, affiliates, members, officers, employees, attorneys, and representatives.
7. Any other entity or individual associated, related or affiliated with (i) the entities referenced in sub paragraphs (a), (b), (c), (d), and (e), above, (ii) the development of the medical office building at 9618 Huebner Road in San Antonio, Texas, (iii) the development of the medical office building in Boerne, Texas, (iv) Michael Horrell’s direct or indirect membership interest in Foundation, or (v) any settlement agreement Horrell entered into with the Foundation. This list includes, but is not limited to the following: Sage Bariatric, Stahl Medical, LLC, Hill Country Digestive Health, PLLC, United Surgical Partners International, SOBO Medical Building, LLC, SMASA Investments, LLC, Slay Engineering Co., Inc., Slay Architecture, Matthew Bradley, P.C., Gonzalez, Chiscano, Angulo & Kasson P.C., John J. Gonzalez, Ramiro “Sonny” Cavazos, II, Monica Cavazos, Allen Alvarez, Naveen Kella, Madeline Slay, Michael Slay, Matthew Bradley, Steve Chiscano, and Goriana Alexander. The claims against Goriana Alexander sought to be sold are specifically limited to claims arising out her ownership and management of Voltaire and FCF and specifically excludes any claim the Estate has against Goriana Alexander for money owed to the Seller or to the Estate for preferences or fraudulent transfers claims.