Amp'd Mobile Affidavit

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Employees who are terminated, however, would normally be entitled to receive cash in lieu of accrued but unused vacation or paid time off upon separation. The Debtor seeks to pay all accrued and unused vacation and paid time off to terminated employees upon separation, which they estimate will cost approximately $4,000 per employee.

B. Independent Contractors

35. The Debtor employs independent contractors (the "Independent Contractors"). The Debtor believes that the Independent Contractors may terminate services if they are not paid amounts owing to them. This would be significantly detrimental to the Debtor's business, and accordingly the Debtor requests authority to pay prepetition amounts owing to these Independent Contractors.

C. Reimbursable Business Expenses

36. Prior to the Petition Date and in the ordinary course of its business, the Debtor reimbursed employees for certain business expenses incurred in the scope of their employment. Based upon historical averages, approximately 50-60% of employees incur expenses monthly aggregating on average $175,000 to $200,000, relating to, among other things, business related travel expenses, business meals, car rentals and a variety of miscellaneous expenses (collectively, the "Reimbursable Expenses"). All of the Reimbursable Expenses were incurred on the Debtor's behalf in connection with employment by the Debtor and in reliance upon the understanding that such expenses would be reimbursed. The Debtor estimates that, as of the Petition Date, the total amount owed for Reimbursable Expenses is no more than $69,900, with no one employee estimated to receive in excess of $10,000.

D. Employee Benefits

37. In the ordinary course of its business, and as is customary for most large companies, the Debtor has established various employee benefit plans and policies that provide employees with medical, dental, vision, disability, flexible spending accounts, life insurance, 401(k) savings plans, and other similar benefits (collectively, the "Employee Benefits"). The Employee Benefits are generally described below:

i. Health Insurance

38. An important element of the Employee Benefits is medical, dental, vision and similar health insurance (the "Health Benefits"). The Debtor maintains programs with an average monthly cost of approximately $119,000.

39. The Debtor currently owes $12,500 for outstanding dental and vision insurance. To the extent that any premiums remain unpaid as of the Petition Date, or any portion of the current month's payment may be characterized as a prepetition obligation, the Debtor seeks to be authorized, but not directed, to pay such amounts.

ii. Life, AD&D, Short and Long Term Disability Insurance

40. The Debtor provides their employees with fully insured life, accidental death and dismemberment, and long term disability insurance. The average monthly cost to the Debtor is $5,000. The Debtor currently owes $10,000 for such benefits, and the Debtor seeks to be authorized, but not directed, to pay such amounts.

iii. 401(k) Contributions

41. The Debtor offers all eligible employees (2) an opportunity to participate in a 401(k) plan (the "401(k) Plan"). The Debtor does not contribute to the 401(k) Plan and pays only a nominal fee for plan administration. All of the payments made by the debtor to the 401(k) Plan provider consist solely of employee funds. As of the Petition Date, $37,340 in funds were scheduled to be wired to the plan provider. Accordingly, the Debtor seeks authority to pay such amounts. Additionally, the Debtor seeks authority to continue the 401(k) plan. The Debtor submits that it is essential for the morale and maintenance of trust of the employees that necessary steps are taken to protect the employees' 401(k) Plan.

iv. Workers' Compensation

42. The Debtor is liable to employees under various workers' compensation policies. Each workers' compensation policy is designed to provide coverage to the Debtor's employees for injuries which are sustained by such employees during the policy year.

43. The Debtor maintains a premium-based workers' compensation insurance plan, with a monthly premium of $24,000. The coverage is current to date.