decisions unless he and Mr. Johnson agree on them. PDS asserts that it cannot pursue decisions in its best interests unless Dan Leckrone goes along with them, but he consistently places Alliacense’s interests ahead of PDS’s or TPL’s interests in communications with PDS.

V. THE DEBTOR’S REPREHENSIBLE BEHAVIOR THIS CASE.

a. As set forth more fully in the Felcyn Declaration, the Johnson Declaration and the DECLARATION OF CLIFF FLOWERS IN SUPPORT OF MOTION OF CREDITORS’ COMMITTEE FOR ORDERS: (1) DIRECTING THE APPOINTMENT OF A CHAPTER 11 TRUSTEE; AND (2) DIRECTING THE DEBTOR AND DANIEL E. LECKRONE TO APPEAR AND SHOW CAUSE WHY THEY SHOULD NOT BE HELD IN CONTEMPT OF COURT FOR VIOLATION OF THIS COURT’S ORDER, in an effort to intimidate Committee members into submission, Mr. Leckrone has threatened unmeritorious litigation against at least one committee member. Such bullying should not be tolerated by this Court, and the Debtor, a trustee for the estate, should not be allowed to persist in such conduct.

b. The Debtor has collected over $7,000,000 and perhaps more in unauthorized settlements in 2013 and has yet to reserve one cent for the benefit of creditors. If this conduct is allowed to continue, the Committee is convinced that creditors will receive nothing in this case.