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Re: None

Thursday, 07/21/2011 12:06:07 PM

Thursday, July 21, 2011 12:06:07 PM

Post# of 3167
New deal proposed, better for us!

Alexej Ladonnikov (largest shareholder) has proposed a deal and has the backing of the UST along with shareholders that represent 30% of the O/S. IMO this is why the judge delayed ruling on the CXM sale and IMO will probably deny it completely unless CXM can make a better offer.

Mr. Ladonnikov has 1 million dollars in this and in his plan the commons remain intact.

Ladonnikov has decided to withdraw his support for the Sale Motion and instead desires to work with DermaStar and the Debtor to craft a plan of reorganization that will result in a substantial recovery for the Debtor’s creditors and existing equity holders.



F. DermaStar and Ladonnikov are Prepared to Negotiate and Fund a Plan of Reorganization with the Debtor.
In contrast to the Sale Motion, which strips the estate of any upside of the successful commercialization of its product and yet subjects the estate to considerable risk, DermaStar and Ladonnikov (collectively, the “Plan Sponsors”) are prepared to negotiate and, if an agreement can be reached, fund a plan of reorganization which will allow the Debtor’s creditors and shareholders to realize immediate and future dividends. In short, the Plan Sponsors are prepared to provide immediate funds to pay administrative expenses and a portion of the Debtor’s unsecured claims on confirmation; sufficient operating capital to complete the second Phase 3 trial; an experienced board and management team to oversee the final Phase 3 trial and, if approved, bring the product to market; and a commitment to bring the product to market. The Plan Sponsors, which include the Debtor’s largest unsecured creditor, believe that a plan of reorganization will yield a greater recovery for the Debtor’s creditors and shareholders without the additional risk of significant losses from Cardium’s business lines with significant historical losses.



The documents have just been posted to the court website:
http://ia600607.us.archive.org/33/items/gov.uscourts.casb.348892/gov.uscourts.casb.348892.docket.html

Opposition to Debtor's Motion to Sell Substantially All Assets of the Estate Free and Clear of Liens, Claims and Interests and Assume and Assign Certain Executory Contracts without Overbid filed by Matthew J. Riopelle of Foley & Lardner, LLP on behalf of Alexej Ladonnikov.
http://www.archive.org/download/gov.uscourts.casb.348892/gov.uscourts.casb.348892.20.0.pdf

Declaration of Michael Corwin In Opposition to Sale
http://www.archive.org/download/gov.uscourts.casb.348892/gov.uscourts.casb.348892.20.1.pdf

Reply to Opposition to Debtor's Motion to Sell Substantially all Assets of the Estate Free & Clear of Liens Claims & Interests and Assume & Assign Certain Executory Contracts without Overbid filed by Michael D. Breslauer of Solomon Ward Seidenwurm & Smith, LLP on behalf of Transdel Pharmaceuticals, Inc.
http://www.archive.org/download/gov.uscourts.casb.348892/gov.uscourts.casb.348892.24.0.pdf