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IN THE UNITED STATES BANKRUPTCY COURT

FOR THE DISTRICT OF DELAWARE
Chapter 11
CRDENTIA CORP., et al./ Case No. 10-__ _
Debtors. (Joint Administration Requested)
MOTION OF DEBTORS AND DEBTORS IN POSSESSION
FOR AN ORDER AUTHORIZING THEM TO PAY INSTALLMENTS
UNDER INSURANCE PREMIUM FINANCING AGREEMENT
The above-captioned debtors and debtors in possession (collectively, the
"Debtors"), hereby move the Court for the ently of an order, pursuant to section 105(a) and
363(b) of title 11 of the United States Code (the "Bankruptcy Code") authorizing the Debtors (a)
to pay all valid, outstanding pre-petition obligations to Heritage Premium Assignment Company
("Heritage") pursuant to a pre-petition Commercial Premium Finance Agreement dated in July
2009 (the "Premium Finance Agreement"), attached hereto as Exhibit A and incorporated by
reference, by and between Crdentia Corp. ("Crdentia") and Heritage and (b) to pay all post-
petition monthly installments of the Premium Finance Agreement as they come due. In support
of this Motion, the Debtors respectfully request as follows:
The Debtors, along with the last four digits of their federal tax identification numbers, are: Crdentia
Corp.(5701), ATS Universal, LLC (3980), Baker Anderson Christie, Inc. (3631), CRDE Corp. (2509),
GHS Acquisition Corporation (9736), Health Industry Professionals, LLC ( 4246), HIP Holding, Inc.
(3468), MP Health Corp. (4403), New Age Staffing, Inc. (1214) and Nurses Network, fuc. (6291). The
Debtor;' mailing address for purposes of these cases is 1964 Howell Branch Road, Ste. 206, Winter Park,
Florida 32792.
Jurisdiction
1. The Court has jurisdiction over this matter pmsuant to 28 U.S.C. 157 and
1334. Venue is proper pmsuant to 28 U.S.C. 1408 and 1409. This is a core proceeding
pmsuant to 28 U.S.C. 157(b)(2).
2. The statutory predicates for the relief requested herein are sections 105 and
363(b) of the Bankruptcy Code.
General Background
3. On March 17, 2010 (the "Petition Date"), the Debtors commenced these
reorganization cases by filing voluntary petitions for relief under chapter 11 of the Bankmptcy
Code. The Debtors are continuing in possession of their property as debtors in possession
pursuant to sections 1107 and II 08 of the Bankmptcy Code.
4. No request has been made for the appointment of a trustee or examiner.
The Insurance Premium Finance Obligations
5. In connection with the day-to-day operations of their business, the Debtors
are either required by law or compelled by sound business judgment to maintain various forms of
insurance, including general liability, professional liability, locum tenens claims, property,
automobile, fiduciary liability, crime, umbrella coverage and excess umbrella coverage. Certain
insurance policies obtained by the Debtors to provide such coverage require the Debtors to
prepay the full premium for the applicable coverage period. Because all of these insurance
policies cover policy periods 12 months, the requirement to prepay the full premium would
impose a significant financial burden on the Debtors. To lessen this burden, prior to the Petition
Date, the Debtors financed the premiums for certain insurance policies (collectively, the
"Insurance Policies") pmsuant to the Premium Finance Agreement with Heritage.
2
6. Pursuant to the Premium Finance Agreement, Heritage paid the premiums
due under the applicable Insurance Policies, and the Debtors thereby became obligated to repay
$568,055.74 for the amount financed under the Premium Finance Agreement in installments over
the term of the Premium Finance Agreement.
Premium Finance Agreement
7. Pursuant to the Premium Finance Agreement, Heritage paid an aggregate
of $688,902.41 in insurance premiums to the issuers of certain of the Insurance Policies. In
retum, the Debtors paid $120,846.67 of the aggregate amount to Heritage upon execution of the
Premium Finance Agreement and financed the remaining balance of $568,055.74 over nine (9)
months at an annual interest rate of 6.460 % and with finance charges of $15,399.59. The
Debtors' monthly installment of $64,828.37 to Heritage is due on the 25
1
h day of each month,
commencing on August 25,2009.
8. The Premium Finance Agreement contains an in-evocable limited power
of attomey granted by the Debtors to Heritage. Pursuant to this power of attomey, if the Debtors
default on their payment obligations under the Premium Finance Agreement, Heritage may
cancel the Insurance Policies
2
Upon such a cancellation, Heritage may be entitled to collect or
receive any unearned premiums refunded by the issuers of the Insurance Policies as well as any
loss payments which may become payable under the Insurance Policies.
9. As of the Petition Date, the Debtors are current with their obligation to
Heritage. The next installment payable by the Debtor under the Premium Finance Agreement is
due on March 25, 2010.
2
From and after the Petition Date, Heritage's ability to utilize this remedy is limited by and subject to the
terms of the automatic stay imposed by section 362 of the Bankruptcy Code.
3
Request for Authority to Continue to Perform
Obligations Under the Premium Finance Agreement
10. If the Debtors do not pay the postpetition installments pursuant to the
Premium Finance Agreement as they come due, Heritage could seek relief from the automatic
stay to terminate the Insurance Policies. If Heritage succeeds in such a request, the Debtors
would be forced to seek replacement insurance coverage. Even if the Debtors were able to
procure replacement insurance coverage, it is doubtful that the Debtors would be able to do so on
terms and conditions as favorable as those presently in place under the Insurance Policies.
Moreover, there is no assurance that the Debtors would be able to obtain replacement insurance
quickly enough to prevent a lapse in coverage.
11. To ensure that (a) the insurance coverage provided under the Insurance
Policies is not inten11pted and (b) the Debtors are not forced to procure replacement insurance
coverage on less favorable terms and conditions, the Debtors must be able to continue to perform
their obligations under the Premium Finance Agreement. The Insurance Policies for which
premiums are financed under the Premium Finance Agreement provide the Debtors with a wide
variety of essential insurance coverage. Any intenuption in such coverage would expose the
Debtors to serious risks associated with lapses in coverage, including (a) direct liability for
payment of claims that otherwise would have been payable by the Insurers under the Insurance
Policies, and (b) the possible incunence of material property damage costs and other losses that
otherwise would have been reimbursed by the Insurers under the Insurance Policies. The
Debtors thus believe that maintaining continued and uninten11pted insurance coverage under the
favorable terms and conditions provided by the Insurance Policies clearly is in the best interests
of the Debtors and their estate and creditors. Accordingly, the Debtors seek authority to pay all
of the postpetition installments under the Premium Finance Agreement as they come due.
4
Relief Requested
12. By this Motion, the Debtors seek authority to continue to perform their
obligations under the Premium Finance Agreement. In light of the importance of maintaining
the insmance coverage with respect to their business activities, the Debtors believe that is in the
best interests of their estates and creditors for this Court to authorize the Debtors to honor their
obligations under the Premium Finance Agreement.
Basis for Relief Requested
13. Bankruptcy Code section 364(c)(2) provides, in pertinent part:
If the trustee is unable to obtain unsecmed credit allowable under
section 503(b)(1) of tills title as an administrative expense, the
court, after notice and a hearing, may authorize the obtaining of
credit or the incurring of debt-
. . . (2) secured by a lien on property of the estate that is not
otherwise subject to a lien[.]
11 U.S.C. 364(c)(2). In other words, section 364(c)(2) authmizes, after notice and a hearing, a
debtor in possession to obtain debt seemed by a lien on property of the estate.
14. The above requirements are met here. Generally, lenders are unwilling to
finance insurance premiums on an unsecured basis. Under any new premium finance agreement,
the counterparty would likely require that the Debtors grant a secmity interest in the unearned
premiums under the financed policies. See, generally, In re Schwinn Bicycle Co., 200 B.R. 980,
982 (Bankr. N.D. Ill. 1996) (describing insmance premium financing agreements). The Debtors
are unaware of any insurance premium finance company that would agree to extend such credit
on an unsecmed basis, including Heritage.
15. The Debtors have compelling business reasons for seeking to continue the
Premium Finance Agreement The insurance coverage provided under the Premium Finance
5
Agreement is essential for preserving the value of the Debtors' assets and, in many cases, such
coverage is required by various regulations, laws, and contracts that govern the Debtors'
business operations. Indeed, maintenance of insurance policies, including the coverage provided
by the Insurance Policies, is required by the operating guidelines established by the Office of the
United States Trustee. See 3 UNITED STATES TRUSTEE MANUAL, 3-3.2.3 (Oct. 1998) ("A
debtor much obtain appropriate insurance coverage, and documentation regarding the existence
of the coverage must be provided to the [Office of the] United States Trustee as early in the case
as possible.")
16. In addition, the Debtors have determined in the exercise of their business
judgment that the prudent management of their cash requires that the insmance premium
payments be financed in accordance with Premium Finance Agreement. Proper cash
management is vital to the Debtors' reorganization, and thus, the relief requested in this Motion
should be granted.
17. The only assets in which Heritage will have a security interest under the
Premium Finance Agreement will be those sums payable under or in relation to the Insmance
Policies, and the security interest granted to Heritage will only secure the Debtors' remaining
payment obligations to Heritage under the Premium Finance Agreement. Therefore, the security
interest granted under the Premium Finance Agreement will encumber only an asset of the
Debtors that will come into being by virtue of the financing provided by Heritage pursuant to the
Premium Finance Agreement.
18. The relief requested in this Motion is commonly granted in bankruptcy
cases in this and other districts. See, e.g., In re Taylor-Wharton International LLC, No. 09-
14089 (BLS) (Bankr. D. Del. Jan. 28, 2010); In re ACG Holdings, Inc., No. 08-11467 (CSS)
6
(Bankr. D. Del. July 16, 2008); In re Pope & Talbot, Inc., No. 07-11738 (CSS) (Bankr. D. Del.
Dec. 7, 2007).
19. For the reasons stated above, the Debtors believe that continuing to pay
their obligations under the Premium Finance Agreement represents the reasonable exercise of the
Debtors' business judgment. As noted above, section 364(c) authorizes a debtor, in the exercise
of its business judgment, to incur secured debt if the debtor has been unable to obtain unsecured
credit and the borrowing is in the best interests of the estates. See, e.g., In re Budget Group, Inc.,
No. 02-12152, 2002 Bankr. LEXIS 1050 (Bankr. D. Del. Aug. 1, 2002) (court authorized
funding of acquisition of property on a secured basis where acquired property was necessary to
maintain operations and debtor could not obtain such funding on an unsecured basis); In re Ames
Dept. Stores, 115 B.R. 34, 38 (Bankr. S.D.N.Y. 1990) (with respect to postpetition credit, courts
"permit debtors-in-possession to exercise their basic business judgment consistent with their
fiduciary duties"). Because a bonowing to maintain essential insurance coverage is in the best
interests of the Debtors' estates and there is no alternative method of obtaining insurance
premium financing, the Comi should authorize the Debtors to continue with their obligations
under the Premium Finance Agreement. Moreover, any interruption in insurance coverage
caused by the Debtors' inability to pay prepetition claim amounts or to generally satisfy their
obligations as they come due under the Premium Finance Agreement and the related Insurance
Policies would cause immediate and irreparable harm to the Debtors' estates. Furthermore, the
ability to finance the Insurance Policies is crucial to the Debtors' ability to manage their cash
flow. Accordingly, the Debtors hereby seek authority to continue the Premium Finance
Agreement and make all payments as they come due.
7
Notice
20. No trustee, examiner or creditors' committee has been appointed in these
chapter 11 cases. Notice of the Motion has been provided to: (a) the U.S. Trustee; (b) those
pmiies listed on the consolidated list of creditors holding the twenty (20) largest unsecured
claims against the Debtors, as identified in their chapter 11 petitions; (c) counsel for ComVest
Capital, LLC, the Debtors' secured lender; and (d) Heritage. In light of the nature of the relief
requested herein, the Debtors submit that no other or fiuiher notice is required.
No Prior Request
21. No prior request for the relief sought in this Motion has been made to this
or aoy other court.
Remainder of Page Intentionally Left Blank
8
WHEREFORE, the Debtors respectfully request that the Court enter an order,
substantially in the form attached hereto as Exhibit B: to (i) pay all valid, outstanding pre-
petition obligations to Heritage pursuant to the Premium Finance Agreement; (ii) authorizing the
Debtors to pay all postpetition installments under the Premium Finance Agreement as they come
due; and (iii) granting such other and further relief as the Comt may deem proper.
March 17,2010
Wilmington, Delaware
BAYARD, P.A.
Is/ Jamie L. Edmonson
Jamie L. Edmonson (No. 4247)
222 Delaware A venue, Suite 900
Wilmington, DE 19801
Phone: (302) 655-5000
Fax (302) 658-6395
-and-
GERSTEN SAY AGE, LLP
Paul Rachmuth
600 Lexington A venue
New York, New York 10022
Telephone: (212) 752-9700
Facsimile: (212) 980-5192
Proposed Counsel for the Debtors and
Debtors in Possession
9
EXHIBIT A
Premium Finance Agreement
Originated By Heritage Premium Assignment Company
Ucensed Address: 109 Dunford Olive
Healh, TX 75032
to First
INSURED/BORROWER (Name and addmts as sllQW.n on Polley)
Crdentla Corporation
5001 LBJ Freeway, Ste, 850
Dallas TX 75244
Telephone Nurnber. (214) 276-0442
Direct . Randall Turnbull
AGENT or BROKER (Name and Sus!ness Addres5) 091000036
Swingle, Co!Uns & Associates
13760 Noel Road
Sutfe 850
Dallas TX 75240-7332
(972) 387-JOOQ
H,.rna.nF Premium Assignment Company
Insurance Funding Corp.
Suite 1000
F/D: 015
Prnpayment The Insure<! may prepay the full amount dtJe and
receive a refund of the unearned Interest as provided
on page 2 of this agreement.
Sec;urify As securi(y for the payments io be rnade, the inslJ!Etd
a5slg_nsHe_rftage PremiUm Ccxnpany
(herem rnferted to as "lENDERH) a sacu/iW interest in
f&tum premiums, dividend payments_. and cert.:Uo loss
P.aypl(:mts With reference to the policies fisted beGiow.
Under certain conditions, LENDER HAS THE Rl HT
TO CANCEl FINANCED POLICIES, as provided on
page 2 of this a grOOm ant,
072309 CFG:Xnt&XDal
Polley Number
Aritl Prefnc
FLJ>()OOS483-<J4
(P-IJffcJes continued on nexf:p;;ijJe.)
COMMERCIAL PREMIUM FINANCE AGREEMENT
AND DISCLOSURE STATEMENT
SegfnrRng 08125/.2009
Late A (ate chate wlfl be on payment which is oof
Pa)'menl b lENDER wlthtn five (5) C:lays of -Its due: date
nloss a 011gor grace oenc'Js specffiea vntler aoeUcahlo
aw, rn Whtcti case a Jete c n; Wlll
1
be- rmposea
RYillont not .bY v.11h n UOh "'""" pe
tlr'.Jt.h':]g, Y.\'ll,'!bt.'TJ, ... ,d
Js I8S$. lhe mwdmumlru:e charge 1S li5.00 u , Mf; an
ND,
Contract Reference should be to the telllls of lhls as
stated berow 1\nd on page . 2 for fnfoffllalion about
nonpavment, default, J>Mcellafion, tho ngm to demand
Immediate payment f11 full, and prepayment.
"'""
Polfcy Term Effective Oat&
In Months. Mo. Day, Yr.
PROF 12
{ME%: 15000 10)
PROF 12
{ME%: '10]
07-25-2009
FIN TXS/FEES
ERN TXSIFEES
07-25-2009
FIN TXSJFEES
ERN TX\l/FEES
NO'llCE: SEE PAGE 2 FOR IMPORTANT INFORMATION .
The provisions on pa{le lneorporatad by Jlll:ferance and constitute a part ofthir; agreement
INSURED'S AGREEMENT:
lUI MiENIT<lR RE:PRESENTAliONS AND WARR.ANTIES ln consideration of the pramium Ravmenls (the "Amount Financed" above) to be
made to ffle above captioned AGENT -or BROKER. bY. the named msur&d
lharoln ro.lorred to .. 'Jnsured'l oromlsad to pay, to !he oroer of lENDER, the
ToWI of t->aymen!s subject to al ol tne provisions set forth on both pages of thfs
agreement.

Slgnature of Agent or Broker
111/e
NOTICE TO THE INSURED:
{1} Do not thfs agroement before
brank

enutled to a c.orrffllete{Y-fll ed-
of thl Under the Ia ,
you hav"b the h! to pay: off n Name of Insured (Print or Type)
advanco fh.e fir! amount and
under condition$ to obr&ln a
partial refund ofthe seMc& charge.
{4} Keep your copy of this a.greemant By. Signature
tQ p.rotecl:your legal rights. -------------
5G, 1.21.., lf7 J?So
ADDmONAL PROVISIONS OF PREMIUM FINANCE
WARRAN'TY OF ACCURACY. The lnslJrecl represen!s and warran1s l..ENDER INTEREST llUE AFTER CANCELLATION. TQ the permfltad by applicable
lhet the. lnstJJanoe polldes listed In 1he SchedUle of Policies am In rurr force and law, If cance?laUon occlU$, the Insured agrees to pay LENDER Interest on lha
effect and that Ute has- not as$1gned' any lnteoosl in the polrcks except for balanoe due al tlul <:ontmct ral& or at 1hf! maxrmum rate allowed by app/H:able law
the- lolme.;t of mortgagees and IQ!iS payees, The lnsured furthe:r repmaen!s- and' Wflk;hevet Ia less, 1,1nlll the balant;e- Is paid In fulf or unlli such other dele <'IS provid!KI
warrants to LENDER that: {J) none of the /Murance policies Jlsled In the Schedu!& by applicable Jaw.
Gf Polfcies SM for (amUy ot hoUsehold purposes, atu;l {II) the Insured has
no lnd&bWdneS9 to the Insurers Issuing the nsted Jl(llleles am;! none ot those RIGHT TO DEMAND IMMtaliAT:E PA'r'MENT JN FULL. A1 any 11me altar default,
insuNrshaveasserlad!myelalmsforpaymaniagalnstltJefnsumd. L.ENQER can demand and has the light to Immediate payment of the tutal
unpaid amount due under lhls agmemenl even If- Ll:lNDER hils nat any
REPRESENTATlON Ol= SOLVENCY. The ln11ured repfflsents thal lhe Jnaumd Is tefuntlofunellmed pwm!Urn.
not Insolvent nor subjecl oJ any CANCEl.LATI:ON 11 a default br th& Insured resulls In cancellation of any
COLLATeRAL.. To secure- paYiflent of all amounts. due vnder this JnstnanQit po!lcv /!Sled In the Suhedule a Pollcles, the Insured wlll pay LENOER a
ltJsured grants LENDER a interest In fhe polldes, fncludlng aU telum chargeequa!lolhtHnijld"mumcl'tafyepennlttedbyiaw.
<IMdend and loss payments whlch JtidUCt.l unearned
prem)l.lms, subject to env mortgagee or loss
RIGHT TO CANCeL. Jr lnsurnd does not make a when lt duo. or If
Insured is Ill defatJ!l mder !his lENDER I'Tl!Y cancel the
and act In lnwred's place with regaro to the pollcle$, indtldln'l. endorsing
any c!Jeck ot draft Issued in Uw Insured's rot funds assigned fg !:NDj:;R as
securfly herefn. This- ri;ght given by Insured to LENDER comrlitu!es a "Power of
Marne}"'. Before LENDER cancels !he LENDER will provide nollc:e lo
lhe lnstnW, as- required bv law. lnstJtod agress- that !his rklht llJ. canool which
Insured has- granted to be revoked, and !hiD: U!NbER'$-rt;ghl to
cancel will fermlnale only after aU of rnsur&d's lndebladt1e6S under this agreement
fs paid In fUll.
DEf:AULT. Insured Is In defaull under !his agreement if, {a) a payment fs not
reCeived by l.END!m 1.\lhen II Js dUe, (b) Insured or Its are
Insolvent or Jnvo]Vtid In a .bankruptcy- or Simlfar proceeding -as- a debtor, {c) Insured
falls to -compl_y with any of uw lell'rls- of this agreemel'll. (d} tnsuram;e companies
-Ci:!ncel coverages, (e) premiums !nerease under any policy lhi!ed In this a,greemonl,
and Insured falli!! to pay -SUch increased premium Within thirty (30) days ol
noUHcatlon, or (f} lnsumQ Is In del'aull under any ()!her agreement Willi lENOER.
Wherewr the wOrd Ia wed In thl!i agreamsnt.. it means any one or the
II 1tle Insured is In defaull, LENDER has no further Obligation uru:klr thls
agreGment !o pay premlUITI$ on the lneuted's behalf, and lENDER m<ty pursue any
of the ratnodles ptOV!ded In this agreement.
LATI: CHARGI;i$, A late ch<true Wlll be lm(ll)S9d on any payment which Is not
by LENDER wlthfn ffve (6) days or lis due dale (Unfe6S a longer (l;ace
period Is &peciRed under ;appllcabfa- le!W, In Which case a fate charge Will be
lltlpostJd on .anY !JBYmanl not recelvrui by LENDER WllhTn a!Jeh graCe PSfod} This
lata olu11ga wur be 5% or the overdue amount or the maklml.lm late oliarge
psrmJttad by applicable Jaw, whtchaver Is Jess. The lna}d'mum late charge Is $5.00
in DE, MT, and NO,
DISRONOI'lto CHECk FEE. If an lnsumti's check Is dl6honored ror any reason
and If permltmd by laW, tho WiJ[ pay LENDER e dll>honored Check rea
to the rna!dmum fee perm!Ued bylaw,
PAYMENTS RECEIYEOA.FTatNOTICE OF CANCElLATION. Once a Notice of
Canctlllatlon ltas been sent to any Insurance oompany, LENDER baSI no duty to
rescind II or to ask that the polk;y_ be evan If lENDER later receives
Insured's paymanL Payments WhiCh l..E:NDER ret:el\1'$11 aRer sanding a Notice of
cancellallon may be appt/Eid to /nsurud'&_ eC<XIunt Without changing any of
Lf::NDER's rlghls under !hl!l agreernenl
LENDEA.'S RIGHTS AFTR THE POLICIES ARE CANCELLEr). After any policy Is
cancelled [whether by Insured or LENDER or Ql'lyone elsellENDEFl has tha right
to recslvlit 811 unB<Ifne<f prellliums and -other fund&- asslgn&cf to LENOER as aecufily
herein to BllDIY lhum to ln:Jured's unpdd balance under this agreement or any
olher e_greement "batwaan the IJ1S1,1red alld LliNDER.Ifthe amount _fllCelved Is more
than the .amounl owAI;I by Insured, any amnunt will bEl- reft1nd&d to rnsUJtld.
'' the amount reoelvQCI is less Uum the amoun! owed bv ill!lured, lnsllffl(f wlU pay
LeNDER the belom(:e due. LENDER may act lo lnsured'"s place to dO whatever fs
neawsary 1<> collect sur.;h refunds. Th& lnsumnc comoanlas may m!Y on Whate-ver
LENDER tells them regarding Cha policies; does nm: flf!ve to any PIQOf from
Insured oranyona e[SQ.
ASSJGtlMENTS. 11J8Y not eqalgn any policy "Mthout I..ENDEifs- WJ'itlen
oonsenl However. LENDER"$ ronsent ls not needed to add murtmJ;gees or other
persons as loss payetW. LENOE;R may lram;Jer ils righls !hi$ agr&(ffnen! to
anyone wllhOI,II: !hlil' OO!l5ent of /flsurad.
COLI..ECTJONS Atm ATTORNEY FEES. LENDER may enroroe It$ rl;ghts to tolla<:l
amounts dua to ft without usjng the security itlleff35t In this '!gree!mai!L If
LENDER uses an atmlnY \linD Is no! a salaried ernptoyeg f !..ENDER or rncurs
-other wllectron costs to eollecl $flY. mp)ley owad under !his -agreement, lllsuwd
to f!B.Y- reasonable attorney fees; court o:miB, and o!h.or collection casl.!i
lncurr&d by LENDER, nr;>l to 20 paroent of the amount dU& and payable under
lhla a.gruernenl.

PREPAYMENT. At any time, lnsurod may pay ltle enllr$ amount sHU ungatd, If
lllSured paYs the ruq unpaid amount baforu It Js due,'fnsllllld will a rehlnd of
unearned Finance Charge computOO by the actuarial method or the RulE! of 7B-'$, as
bY appllcat)la law. TtJJs roftmd will ba .subJact to the mmd'mum
llOJI.ferundabla- stzNIOO fee PB'rmHted by_ applicable taw. Th&rn Is nQ refund made if
the amount to bo refunded is lese than $1.00.
AUDrr AND QEPORTlNG FORNI POLICJES. Wllh t;4.!gard to any policy in the
Schedule Qf P.oUclas, which !s an auditable or raPOrlli11Jrorm lypa, Insured agrees 1o
Promptly pay 1o the insurance company the between tho actual eaml'td
prefl'llWil {lenaiillad for lha po!Jcy. and the premiums ffnancSd undgr this agreement
:FfNANCE CHARGE. The finance charge begins l)n tho .gm!fesl eff&G!Ive dale of Qle
DDIIcles. listed fn tile Sch!O!duk!l of P'ollcles MH;:tlon. The finance charye !IKlfu(l'es
interest and may Include a non-refundable &ervfca fee to lha 111ax!mum feu
perm/Had by The11nl'll'lt8 charge fs compu!ed using a 365 daY year.
AGENT OR BROKER.. The a.ganr or bro){w handling this agseenumt Is not the aae:nf
or OrokBr-oflENDER, and cannot le.gallyblnd LENDE!R in any way.
permlSslble by law some- portion offhlr:; ifnance charge maybe paid by LENDER to
theagentorbroker oxeciiilng this agroement as payment for the servfc.as In mm:klrlng1he
finanCing of too Insurance Any snda/1 queslkms &boot !his pa}lment shotlk,t
ba directed lo !he ag:entor"brokBr.
CORRECTIONS. LENDI:R ruay Insert the names of th& lnsurtmoo companies and
_policy

If these are not known el the Urne lnsumd signs !his agreement.
LENDER !a aumodzed 10 correct patent eJTOfS or omissions In tflls agro&ment.
EFFECTIVE bATE. This agreement will not .become until II ts acceplarl fn
wrttlng by LENOER.
GOVERNING J.AW. Is by and under the laws
of 100 'Sial& wher& l.l:NbER accept!!; this :agmemenl. In AR, this .agreement shall b&
governed bv the Jaws of the> s!ale of 11... If anyt::ourt tlnd$ Dart Of thll;l ameement
to be SJ,ich finding $hah not affoot the remalnder Df tllfs sgroemonl Stngu!ar
word's In thrs agrvernenl shall mB{!II'I .P.Iural tind vl(;:e verna as may be: _ _p:q\IJred to give
the aglGQl\'\$nf. mean! ng. North Carolfrni Depsrtment of Insurance Penni! 11'6-.462.
SIGNATURE AND ACKNOWLEDGMENT. Insured has thla. agtGement and
recelved a copy of H, If Insured fs a OOIPQ!llUon, tile person signing is an officer of
that co!JXnSI!on autlwrit.Eid to skm this If the lnsum:d IS- not a
corpO!<ItiOil, all lrmure<ls listed in anypDifey haves
WABli-JTY, lnsuffld understands and NO.ER hEU;. no Uabllilyto Insured
or any pcrwn or entHy upon Ule exercise of LeNDER'S IlrJht -of caracellaUon, except
Jn the ev&n! of wiUrul wfuf&n1i(mat ml8C01ld\.1Gt by lENDER.
AGENT OR BROKER REPRESENTATIONS AND WARRANTIES
the lnsur6d'.$ s1gneWre Is DEp0SITIPROVIS/ONAL PRaMIUMS. Any Audit or Reporting Foml policies or
policies subject to llllrospectlve Included Jn this agreement are tlQied b$10Vf In
sectloll (a). Ths doJK)Sit (11 provisloo<il Pmt:tlums for 1Msa POlicies are no! kiss !han
lhunUclpal$d PlliiTIIUms to be e8med tor ll\8 full term of lhll policies.
or !Ills
the b&s! of our know!OOge, neither the Insured nor the
<1re Insolvent Dr InvolVed frt a bani(OJplcy or similar
, OJXCBp! as clearly fndicaled Dn page 1 oflh[s agreement.
FOR THE SCHeDULED POLICIES, AGENT OR BROKER WARRANTS 'fRAT:
(a) No policies are Audl!eble, ReP9f'iil!g form policies or po}JC!eS S1,1blact lo Retrospetlive
Rellng, except polfcfes lfsled at rfsl:it or as fndfce.ted on !he Sched"ula of Policies.
t.OSS PAYEES NAME;D. Anv pot!ctes Which provide that 100 pr&miUJTt may be
eamed earlier Jn tile evenl of loss. e.re- nDted below In section (bJ and/qr {cl. The
ht!S no!lfied !he companJoo ani:f the Insure& that
lENDER l9 IDbe munedas. a /OS$ payee--on any such. poiloles.
AUTHORIZED ISSU!N:G AGENT. For !he !OehadUied policies, !he Agani/Brok_er Is
either 1he fnsu!'ilnce CQmpanys authorized policy B9Bnl or "!he broker placing
!he ooVerage dlreclfy vMb the lnSl,lrance rnmpa!l)', except where the name and
addlass of !$:S-Uing Agent or Gan$ral Agent Is lis!Eidln llie Sched"llle of Policies.
and any inslallments
PoJlcy Number
Of EXceptJons Comments
(b) No pdlol"" or.o !'bi,.ttu Mlolm"m Eamoo P"'mim ax<Ot>t oollol,. al ""'" ,,.,
lridicated on lila of,PQIIcles. ThoMlnlmurn Earnl!dPremlum for lls!eOpobcfes Is $ ___ _
[a)
(b)
(o)
(d)
(c) All policies ftrovide !hat unearned pramknns arecompuled by the standard short ralo or
exoepf those policies listed e.t right or as fndfcated on Sdlectufe or
(d) No policies oontllln provisions wltloh prohibit caneellellon ellhsrby the Insured arbyth9
insurance tompan}':v.ilhln ten f1C) -day$, e.JOOept ltlosao policies !1&-led attfghtor
lndfe&IW on the Schedl)]Er of P'oi!Cies
. FiF ST 0206
SCHEDULE OF POLICIES
Polley Number
Arid Prefix
Full Nama OfJnaurance and Nama
and A dress of General Agant
or Company Office to Which Premium I$ Paid
Type of
Insurance
Term
Effectivs Date
In onths Mo. Day. Yr.
Polley
Ptem!ums
'
TBD 02713..005- Chubb Custom insurance Company CRME 12 07-2.-2009 (Looo.o
[ME%: 0.000 C
'Wl
FIN TXSIFEES o.o
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...
r.:i.

EXHIBIT B
Proposed Order
Inre
IN THE UNITED STATES BANKRUPTCY COURT
FOR THE DISTRICT OF DELAWARE
Chapter 11
CRDENTIA CORP., et al./
CaseNo. 1 0 - - - ~
Debtors. (Joint Administration Requested)
ORDER AUTHORIZING DEBTORS AND DEBTORS
IN POSSESSION TO PAY INSTALLMENTS UNDER
INSURANCE PREMIUM FINANCING AGREEMENT
Upon consideration of the motion (the "Motion")
2
of the above-captioned debtors
and debtors in possession (the "Debtors") for entry of an order, pursuant to section 105(a) and
363(b) of title 11 of the United States Code (the "Bankruptcy Code"), authorizing it (a) to pay all
valid, outstanding pre-petition obligations to Heritage Premium Assignment Company
("Heritage") pursuant to a pre-petition Commercial Premium Finance Agreement dated in July
2009 (the "Premium Finance Agreement"), by and between the Debtors and Heritage; and (b) to
pay all postpetition installments of the Premium Finance Agreement as they come due; and this
Comt having the jurisdiction to consider the Motion and the relief requested therein in
accordance with 28 U.S.C. 157 and 1334; and this Comt having determined that granting the
relief requested in the Motion is in the best interest of the Debtors, their estates, creditors and
equity security holders; and it appearing that no other or further notice need be given; and after
2
The Debtors, along with the last four digits of their federal tax identification numbers, are: Crdentia
Corp.(5701), ATS Universal, LLC (3980), Baker Anderson Christie, Inc. (3631), CRDE Corp. (2509),
GHS Acquisition Corporation (9736), Health Industry Professionals, LLC ( 4246), HIP Holding, Inc.
(3468), MP Health Corp. (4403), New Age Staffing, Inc. (1214) and Nurses Network, Inc. (6291). The
Debtors' mailing address for purposes of these cases is 1964 Howell Branch Road, Ste. 206, Winter Park,
Florida.32792.
Capitalized terms used but not otherwise defined shall have the meanings set forth in the Motion.
due deliberation and sufficient cause appearing therefor;
IT IS HEREBY ORDERED THAT:
1. The Motion is GRANTED.
2. The Debtors are hereby authorized and empowered, but not directed, to
pay monthly postpetition installment payments due to Heritage pursuant to the Premium Finance
Agreement as these amounts become due.
3. The relief granted in this Order shall be subject to the Tenns of the
Ratification Agreement, the Budget and (as applicable) the Interim Order or Final Order (each as
defined in the Debtors' Motion to obtain post-petition financing).
Dated: Wihnington, Delaware
March , 2010
THE HONORABLE
UNITED STATES BAN-:-=-=KR=UP=Tc=y=-=JU:-::D::-G-:::E::-
2