SUPREME COURT OF THE STATE OF NEW YORK

COUNTY OF ALBANY
----------------.------...........-------..--....._.------ X

PIONEER BANK,

Plaintiff, : Index No. 907160-19

-against-

.
MICHAEL T. MANN; VALUEWISE CORPORATION
d/b/aAPOGEE, d/b/a OPTIX CONSULTING, and d/b/a
CONSENT JUDGMENT
PRIMACY SEARCH GROUP; ROSS PERSONNEL
CONSULTANTS, INC.; ALWAYS LIVE HOLDINGS,
LLC; KANINGO, LLC; CLOUD PAYROLL, LLC;
HIRE FLUX, LLC; HIRE FLUX HOLDINGS, LLC;
MYPAYROLLHR.COM, LLC; and HEUTMAKER
BUSINESS ADVISORS, LLC,
.

Defendants.

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WHEREAS, Defendants Valuewise Corporation, d/b/a Apogee, Optix Consulting, and

Primacy Search Group (collectively, "Valuewise"), Ross Personnel Consultants, Inc. ("RPJ"),

Always Live Holdings, LLC ("ALH"), Kaningo, LLC ("Kaningo"), Cloud Payroll LLC ("Cloud

Payroll"), Hire Flux, LLC ("Hire Flux"), MyPayrollHR.Com, LLC ("MyPayroll"), Heutmaker

("HFH.."
Business Advisors, LLC ("HBA"), and Hire Flux Holdings, LLC and collectively with

Valuewise, RPC, ALH, Kaningo, Cloud Payroll, Hire Flux, MyPayroll, HBA, the "Borrower

Defendants"), and Michael T. Mann ("Mann", and collectively with the Borrower Defcñdants, the

"Defendants"), by their undersigned authorized signatories, hereby consent to the entry of

judgmcñt in favor of Plaintiff Pioneer Bank on all causes of action in the Verified Complaiñt filed

in the above-captioned action on October 18, 2019, and against the Defendants, jointly and

severally;

IT IS HEREBY ORDERED, ADJUDGED, AND DECREED as follows:

Index # 907160-19 Clerk: SP

Clerk's Office 11/06/2019 08:43:16 PM
Filed in Albany County
 1. Pursuant to Cause of Action I in the Verified Complaint, the Borrower Defendants

consent to the entry of a judgment in favor of Plaintiff Pioneer Bank and against the Borrower

Defendants, jointly and severally, in the ame'1nt of $35,839,912.81, plus pre-judgment interest

from October 16, 2019, until the date of entry of this judgment at the per diem contract rate of

$8,543.08, plus post-judgment interest at the applicable statutory rate of nine per centum per

anmim from the date of entry of the judgment ($8,837.24 per day).

2. Pursuant to Cause of Action II in the Verified Complaint, Mann consents to the

entry of a judgment in favor of Plaintiff Pioneer Bank and against Mann in the amount of

$35,839,912.81, plus pre-judgment interest from October 16, 2019, until the date of entry of this

judgment at the per diem contract rate of $8,543.08, plus post-judgment interest at the applicable

statutory rate of nine per centum per aññüm from the date of entry of the judgment ($8,837.24 per

day).

The terms of this Consent Judgment are ACCEPTED, CONSENTED, AND AGREED TO

by Plaintiff Pioneer Bank and all of the Defendants, by their undersigned authorized signatories,

this 6th day of November 2019.

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By: By
Michael T. Mann Robert J. Alessi

Jeffrey D. Kuhn
DLA PIPER LLP (US)
677 - Suite 1205
Broadway
VALUEWISE CORPORATION Albany, New York 12207-2996
T: (518) 788-9710

By: E: ro ert ales i us.dlapiper.com

Ifichael T. Mann jeffrey.kuhn@us.dlapiper.com

President/Authorized Signatory
Attorneys for Plaintiff Pioneer Bank

ROSS PERSONNEL CONSULTANTS,

INC.

By:

Michael T. Mann

President/Authorized Signatory

ALWAYS LIVE HOLDINGS, LLC

By:

Michael T. Mann

Sole Member/Authorized Signatory

KANINGO, LLC

By:

Valuewise Corporation, Member

Michael T. Mann
President/Authorized Signatory

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 CLOUD PAYROLL, LLC

By:

Michael T. Mann
Member/Manager/Authorized Signatory

HIRE FLUX, LLC

By:

Valuewise Corporation, Member

Michael T. Mann

President/Authorized Signatory

MYPAYROLLHR.COM, LLC

By:

Valuewise Corporation, Member

Michael T. Mann
President/Authorized Signatory

HEUTMAKER BUSINESS ADVISORS,

LLC

By:

Valuewise Corporation, Member

Michael T. Mann
President/Authorized Signatory

HIRE FLUX HOLDINGS, LLC

By:

Michael T. Mann
Member/Manager/Authorized Signatory

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ENTER:

J.S.C.