Mkrtchyan v. Payne — Entry #59: AMENDED 53 MOTION by American LNG Services, LLC, Linden Energy Holdings, Inc., Linden Energy, LLC, Linden Strategies, LLC, Stephen P

Case 4:25-mc-01122 Document 59-1 Filed 09/30/26 in TXSD Page 1 of 12

AFFIDAVIT OF STEPHEN P. PAYNE, SR.
IN RESPONSE TO THE COURT’S SEPTEMBER 30, 2026 ORDER (ECF 58)

STATE OF TEXAS §
COUNTY OF HARRIS :

Before me, the undersigned notary public, on this day personally appeared Stephen P.
Payne, Sr., who, being by me duly sworn, deposed and stated as follows:
hs My name is Stephen P. Payne, Sr. I am over eighteen years of age, of sound mind, and
competent to make this Affidavit. I have personal knowledge of the facts stated in this Affidavit,
and they are true and correct.
2. I am a Respondent in this proceeding. I am also the authorized representative of Linden
Strategies, LLC; Linden Energy, LLC; Linden Energy Holdings, Inc.; and American LNG
Services, LLC (together with me, “Respondents”). I am authorized to make this Affidavit on
behalf of each entity Respondent.
3. I make this Affidavit in response to the Court’s September 30, 2026 Order Denying
Without Prejudice Respondents’ Motion for Extension of Time to Satisfy Monetary Obligations
(ECF 58). That Order requires sworn evidence specific to each Respondent addressing: (1) current
financial condition, including total cash and liquid assets in accounts at any financial institution or
on hand; (2) diligent efforts to obtain funds to satisfy the Court’s September 18, 2026 Order (ECF
52); (3) ability to make a partial payment by September 30, 2026; and (4) anticipated source and
timing of additional funds.
4. I have reviewed the September 18, 2026 Order (ECF 52). The monetary obligation

imposed by that Order is $48,563.00.


Case 4:25-mc-01122 Document 59-1 Filed 09/30/26 in TXSD = Page 2 of 12

I. CURRENT FINANCIAL CONDITION OF EACH RESPONDENT

5. On September 30, 2026, I reviewed the current online banking records for every deposit
account still maintained by me or by an entity I control. Those accounts are held at Wells Fargo
Bank. True and correct screenshots of those records, captured on September 30, 2026 at 11:29
a.m., are attached as Exhibits | through 4. I have no material cash on hand apart from the account
balances stated below.

Stephen P. Payne, Sr. (individually)

6. My only personal deposit account is the Wells Fargo Bank account styled “SPP Personal /
Payne S Everyday Checking,” ending in 9830. As of September 30, 2026, the available balance

in that account is $274.04. A true and correct screenshot is attached as Exhibit 1.

Account Institution Available balance

SPP Personal / Everyday Checking ...9830 | Wells Fargo Bank $274.04
Cash on hand — $0.00
Total — Stephen P. Payne, Sr. $274.04

American LNG Services, LLC

pA American LNG Services, LLC maintains an Wells Fargo Bank business checking account
styled “ALNG Checking,” ending in 4662. As of September 30, 2026, the available balance in
that account is $7.73. A true and correct screenshot is attached as Exhibit 2. Recent activity in
that account includes ordinary-course card payments and a $200.00 transfer from my personal

Everyday Checking account on September 29, 2026.

Account Institution Available balance

ALNG Checking ...4662 Wells Fargo Bank $7.73

Total — American LNG Services, LLC $7.73


Case 4:25-mc-01122 Document 59-1 Filed 09/30/26 in TXSD Page 3 of 12

Linden Strategies, LLC

8. Linden Strategies, LLC maintains an Wells Fargo Bank business account ending in 7110.
As of September 30, 2026, the available balance in that account is $8.30. A true and correct
screenshot is attached as Exhibit 3. A $15.00 transfer from my personal Everyday Checking

account into the Linden Strategies account was pending on September 30, 2026.

Account Institution Available balance
Linden Strategies ...7110 Wells Fargo Bank $8.30
Total — Linden Strategies, LLC $8.30

Linden Energy, LLC and Linden Energy Holdings, Inc.

9, Linden Energy, LLC and Linden Energy Holdings, Inc. do not currently maintain an
account at any financial institution. Those entities no longer have a bank account of any kind.
There is therefore no cash or liquid asset of either entity “in accounts at any financial institution
or on hand.” Linden Energy, LLC is defunct for practical purposes and has no operating funds
with which to satisfy the September 18 Order.

Related non-respondent account reviewed

10. —_‘ In the same review I also examined the Wells Fargo Bank account of Linden Government
Solutions (styled “Linden Govt Sols”), ending in 0350. That entity is not a Respondent in this
proceeding. As of September 30, 2026, the available balance in that account is $0.01. A true and
correct screenshot is attached as Exhibit 4. Recent activity in that account consists of $15.00
monthly service fees funded by small transfers from Linden Strategies, LLC. I do not offer the
Linden Government Solutions balance as funds of a Respondent. The payment plan described
below is funded by a client loan to me and by Linden Strategies, LLC receivables.

11. =‘ The total cash and liquid assets of the five named Respondents as of September 30, 2026,

is $290.07, as follows:


Case 4:25-mc-01122 Document 59-1 Filed 09/30/26 in TXSD = Page 4 of 12

Respondent Cash and liquid assets

Stephen P. Payne, Sr. $274.04
American LNG Services, LLC $7.73
Linden Strategies, LLC $8.30
Linden Energy, LLC $0.00 (no account)
Linden Energy Holdings, Inc. $0.00 (no account)
Total — named Respondents $290.07

12. Apart from the $290.07 shown above, my only asset of material value is my personal
residence. I have no other liquid investment account, brokerage account, or similar holding
available to satisfy the September 18 Order on the timetable set by that Order.

I]. DILIGENT EFFORTS TO OBTAIN FUNDS
13. After the Court entered the September 18, 2026, Order, I undertook the following efforts
to obtain funds sufficient to pay the $48,563.00 obligation in the time allowed:
a. I reviewed every deposit account still maintained by me or by any Respondent entity, which
is the review described in paragraphs 5 through 12 and documented in Exhibits 1 through 4.
b. I requested loans from several business partners and from potential lenders. None of those
partners or potential lenders was able to provide the funds needed to pay the full $48,563.00 within
the time set by the September 18 Order.
c. I explored mortgaging or otherwise encumbering my personal residence, which is the only
asset of material value that I own. I was not able to close a mortgage or home-equity loan in time
to satisfy the September 18 deadline. A residential mortgage or home-equity transaction could not
be originated, underwritten, and funded in time.
d. I did obtain a short-term loan from an existing client in the amount of $16,188.00, which

is available to be paid today, September 30, 2026, as described in paragraph 16. That loan is not


Case 4:25-mc-01122 Document 59-1 Filed 09/30/26 in TXSD Page 5 of 12

reflected in the Wells Fargo Bank balances in Exhibits 1 through 4 because those screenshots show
the accounts before the loan proceeds are applied to the Court’s Order.
14. I have not transferred cash or other liquid assets to an insider, family member, or affiliated
person for the purpose of avoiding the September 18 Order. The small transfers visible on Exhibits
1 through 4 — including a $15.00 transfer from my personal account to Linden Strategies, LLC
and a $200.00 transfer from my personal account to American LNG Services, LLC — were
ordinary-course movements to cover operating items and bank fees, not an effort to conceal funds.
The reason the full $48,563.00 was not paid by the original deadline is that the cash on hand
($290.07) and the financing I could obtain in that period were not sufficient to pay the Order in
full.

Il. ABILITY TO MAKE A PARTIAL PAYMENT BY SEPTEMBER 30, 2026
15. Respondents cannot pay the full $48,563.00 today from cash on hand. The named
Respondents collectively hold $290.07 in deposit accounts. I can, however, make a partial
payment today from a client loan.
16. Today, September 30, 2026, I am able to pay $16,188.00, which is one-third of the
$48,563.00 due under the September 18 Order. That $16,188.00 is the proceeds of a loan from
one of our clients. I will cause that amount to be delivered to Petitioner, through Petitioner’s
counsel, upon the Court’s direction or immediately in partial satisfaction of ECF 52.
17. The remaining balance after that partial payment is $32,375.00.

IV. ANTICIPATED SOURCE AND TIMING OF ADDITIONAL FUNDS

18. —_ Linden Strategies, LLC has monthly clients that pay on net-15 terms each month. Those

monthly client payments total $55,000.00.


Case 4:25-mc-01122 Document 59-1 Filed 09/30/26 in TXSD = Page 6 of 12

19. Those $55,000.00 in Linden Strategies, LLC receivables are sufficient to cover the
remaining $32,375.00. I anticipate that those payments will be received in the ordinary net-15
cycle and that the remaining $32,375.00 can be paid on or before October 15, 2026.
20. | therefore respectfully request that the Court accept the $16,188.00 partial payment being
tendered on September 30, 2026, and extend the deadline to pay the remaining $32,375.00 to
October 15, 2026.
21. If the Linden Strategies, LLC client payments have not been received in time to pay the
remaining $32,375.00 by October 15, 2026, I will cause a status report to be filed immediately
identifying the amounts collected and the additional steps being taken.

V. CONCLUSION
22. Jam not asking the Court to set aside the September 18 Order. I am asking for a short,
defined period — through October 15, 2026 — to finish paying the $48,563.00, after paying one-
third of that amount today from a client loan. The Wells Fargo Bank records attached as Exhibits
1 through 4 show why the full amount cannot be paid from cash on hand today.
23. [| have read this Affidavit. The facts stated in it are within my personal knowledge and are
true and correct.

Further Affiant sayeth-not.

25 ——

Individually and as authorized representative of
Linden Strategies, LLC; Linden Energy, LLC;
Linden Energy Holdings, Inc.; and

American LNG Services, LLC

Stephen P. Payne, Sr.

SWORN ACKNOWLEDGMENT


Case 4:25-mc-01122 Document 59-1 Filed 09/30/26 in TXSD = Page 7 of 12

SUBSCRIBED AND SWORN TO before me on this 30th day of September, 2026, by Stephen

P. Payne, Sr., who is personally known to me or who produced dr ve Lime

as identification.

L Diol tm

Notary Public; (State of Texas
My commission expires: ume 26 , “LOZ

zn MARIO GEORGE WALKER
KS Notary 1D #131194018

aA My Commission Expires

June 28, 2029

EXHIBIT 1
Wells Fargo Bank — SPP Personal / Everyday Checking ...9830


Case 4:25-mc-01122 Document 59-1 Filed 09/30/26 in TXSD = Page 8 of 12

Stephen P. Payne, Sr. | Available balance $274.04 | September 30, 2026

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SPP Personal ...9830

$274.04

Available balance @

Account & routing numbers >

Overview Manage Routing & balance info
Transactions © QSearch = Filter
09/30/2026
ONLINE TRANSFER TO LINDEN STRATEGIES, LLC BUSIN $15.00
Pending
09/29/2026
ONLINE TRANSFER REF #IBO3FKZV3D TO SIGNIFY BUSINESS $54.36
ESSENTIAL CARD XXXXXXXXXXXX3486 ON 09/29/26
08/23/2026
ONLINE TRANSFER REF #IBO3FKZJ6Y TO SIGNIFY BUSINESS $55.99

ESSENTIAL CARD XXXXXXXXXXXX4205 ON 09/29/26

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Accounts Deposit Pay & Transfer Explore Menu


Case 4:25-mc-01122 Document 59-1 Filed 09/30/26 in TXSD Page 9 of 12

EXHIBIT 2

Wells Fargo Bank — ALNG Checking ...4662
American LNG Services, LLC | Available balance $7.73 | September 30, 2026

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ALNG Checking ...4662

$7.73

Available balance ©

Account & routing numbers >

Overview Manage Routing & balance info
Transactions © QSearch = Filter
09/29/2026
CHASE CREDIT CRD AUTOPAY 260927 000000000048234 PAYNE $246.00
STEPHEN
03/29/2026
ONLINE TRANSFER FROM PAYNE S EVERYDAY CHECKING +$200.00

XXXXXX9830 REF #IBO3FKBX6P ON 09/29/26

09/28/2026
AMZ_STORECRD_PMT PAYMENT SEP 28 604578115216830 $312.00
PAYNE,STEPHEN

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Accounts Deposit Pay & Transfer Explore Menu


Case 4:25-mc-01122 Document 59-1 Filed 09/30/26 in TXSD Page 10 of 12

EXHIBIT 3

Wells Fargo Bank — Linden Strategies ...7110
Linden Strategies, LLC | Available balance $8.30 | September 30, 2026

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Linden Strategies ...7110

$8.30

Available balance ©

Account & routing numbers >

Overview Manage Routing & balance info
Transactions © QSearch Filter
09/30/2026
ONLINE TRANSFER FROM PAYNE S EVERYDAY CHECKING +$15.00
Pending
09/29/2026
PAYPAL PURCHASE 260929 GOOGLE FLOWGAME STEPHEN PAYNE $59.53
09/28/2026
PAYPAL PURCHASE 260927 GOOGLE ZYNGA IN STEPHEN PAYNE $5.40
09/28/2026
ONLINE TRANSFER TO AMERICAN LNG SERVICES LLC BUSINESS $325.00
& (S) (4) —

Accounts Deposit Pay & Transfer Explore Menu


Case 4:25-mc-01122 Document 59-1 Filed 09/30/26 in TXSD Page 11 of 12

EXHIBIT 4

Wells Fargo Bank — Linden Govt Sols ...0350
Linden Government Solutions (non-respondent) Available balance $0.01 | September 30, 2026

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Linden Govt Sols ...0350

$0.01

Available balance ©

Account & routing numbers >

Overview Manage Routing & balance info
Transactions © QSearch * Filter
09/01/2026
ONLINE TRANSFER FROM LINDEN STRATEGIES, LLC BUSINESS +$15.00

CHECKING XXXXXX7110 REF #1B0329N778 ON 09/01/26

08/31/2026
MONTHLY SERVICE FEE $15.00
08/03/2026
ONLINE TRANSFER FROM LINDEN STRATEGIES, LLC BUSINESS +$15.00

CHECKING XXXXXX7110 REF #IBOZ6FDE6ENG ON 08/01/26

07/31/2026

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Accounts Deposit Pay & Transfer Explore Menu


Case 4:25-mc-01122 Document 59-1 Filed 09/30/26 in TXSD Page 12 of 12

X Q Need help? (2 ce Sign off

Wire submitted
$16,188.00

You submitted your wire on 09/30/2026 at 12:24 pm Pacific Time.

Status Pending ©

To Arnold and Porter etal
United States

From _ Linden Strategies ...7110
Sendon 09/30/2026 ©
Cutoff time: 4:30 pm PT
Deliver by 09/30/2026 ©
Amount $16,188.00

Wire transfer $30.00

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