Assets of Coffee Services Company

Sale of assets of Mountain Thunder Coffee Plantation Int'l Inc. which includes:

• all tangible and intangible assets described in Gemcap Lending I, LLC's ("Gemcap") loan documents, but not the assets encumbered by a first priority security interest held by Direct Capital Corporation, Leaf Commercial Capital, Inc. Deere & Company or Ford Motor Credit Company, LLC;
• the claims and causes of action against Trent Bateman, Lisa Bateman, and certain family members, including trusts in which they have an interest or are beneficiaries, to acquire or improve certain real property;
• the claims and causes of action arising from the pre-petition assets of the Sellers to acquire or improve the property located at 72-3375 Hawaii Belt Road, Captain Cook, Hawaii (the "Hualalai Ranch Property"),
• claims and potential causes of action against Receiver George Van Buren,
• the estates' interest in the Hualalai Ranch Property,
• the leasehold interests with respect to (a) the real property located at 84-4995 Hawaii Belt Road, Captain Cook, Hawaii (the "Honaunau Wet Mill Property") and(b) the real property located at 73-1942 Hao Street, Kailua-Kona, Hawaii (the "Kaloko Property"), as set forth in rental agreements, provided Gemcap shall pay all amounts required to cure the obligations under these rental agreements, and
• the interests of the Trustee in certain of the Assumed Contracts, provided Gemcap pays all amounts required to cure the obligations under the respective assigned Assumed Contracts. The purchased assets shall not include the Seller's interest in (i) certain claims against Grant Kidani, The Kidani Law Firm, The Kidani Law Center, and their respective attorneys, principals, agents, representatives, successors and assigns; (ii) the claims and causes of action respecting judgments obtained against Kona's Best Natural Coffee, LLC; (iii) certain preference or avoidance claims and actions of the Trustee; (iv) the Trustee's rights under the APA and other related transaction documents; (v) any documents or materials subject to attorney-client privilege; and (vi) any federal and state tax receivables, credits, or refunds owed to the Trustee.