Claims for Sale

Sale of the bankruptcy estate’s interest in and to certain claims as generally described by Christopher Gregg Thomas (“Seller”) in his Amended Schedules filed with the United State Bankruptcy Court for the District of Montana on June 26, 2019, (Dkt. 33) and as further described in paragraph 33, Schedule A/B, “Claims Against Third Parties”, to the extent that seller's claims relate, directly or indirectly, to Prospect Agency Group, Inc. (Prospect), and Randy L. Royal, Trustee in Bankruptcy for Prospect Agency Group, and a named Defendant in Adversary Case No. 18-02039 filed in the United States Bankruptcy Court for the District of Wyoming, including commissions from Progressive and Foremost Insurance Companies, as described in said paragraph 33 of the seller's Amended Schedules A/B. The subject claims are also described by seller in his adversary complaint filed against Mr. Royal at Docket No. 1 in Adversary No. 18-02039, United States Bankruptcy Court for the District of Wyoming, filed before the commencement of the seller's personal bankruptcy case. The interest described herein includes all interest seller and the estate may have solely in his individual name, percentage or fractional interests he may have or share with others, and beneficial or equitable interests he may claim against Mr. Royal.