http://dm.epiq11.com/LBH/Document#maxPerPage=25&page=3

From BS, page 15, LBHI´s General Unsecured Claims under this settlement agreement with LBI totalizes 10.216B. Very close.

I don´t expect too much for next MOR. I think that April´s MOR will be more interesting, after distribution. I want to see why they eventually distributed all the free cash available.

We should hear about Trustee´s distribution during next days. LBIE´s administrator mentioned first days of May in last CC, so I expect similar behaviour with LBHI. I believe it will close the gap.

In Feb. MOR, it was reported 2.235B under LBSF and 2.01B under LBHI, disputed unsecured claims - Restricted cash. Numbers don´t match, maybe cotton could enlight us about this subject. Anyway, LBSF reserves is going to creditors.

It´s possible.

About Cotton´s comment about restricted cash, take a look at PR recently posted about the swiss unit:

The deal, if approved by a judge, will make several hedge-fund managers happy, including Paulson & Co . and Elliott Management. That's because while the Swiss fight was going on, $3 billion was held in reserve for the claim. Now, much of that money can go to other creditors like Paulson and Elliott.

http://investorshub.advfn.com/boards/read_msg.aspx?message_id=87121199

What impact there will be on LBHI´s reserves related with LBF agreement? LBHI and LBF had similar claims against each other in quantity - 14B -

In that forum, they are copying and pasting our posts. I could read some of mine. lol

It was posted by stockbum last week. I agree it is correct. Cotton mentioned that reserves for pending claims -abt. 5.8B - should lower the final payment.

An interesting article. It deserves the reading.

Please, forgive the unaccurate translation by google, it was originally written on spanish. There is some old information - the sale of Archstone and the recent agreement with LBF, but the essence is the same.

The big business of Lehman Brothers
Written by Editor Friday, April 5, 2013 23:27
  
 

Paying 2,000 million avoided to pay 400.000

Bankruptcy has become big business for Lehman Brothers: the payment of 2,000 million has avoided paying over 400,000 million. That is, for every dollar invested, has 'won' 200: A 19,900%.

The September 15, 2008, which at the time was the fourth U.S. bank by assets, Lehman Brothers, filed for bankruptcy voluntary declaration of continuity, known as procedure of 'Chapter 11' in American law. Until then, the crisis of subprime mortgages that had erupted in August 2007 in the U.S., had a very limited effect in Europe and the rest of the world. However, after the announcement of Lehman Brothers, the impact outside the U.S. was brutal and marked the starting point of the greatest economic crisis in Europe since the Great Depression.

Actually, Lehman Brothers had been conducting operations with derivatives, packaged damaged assets and other toxic instruments outside the U.S. primarily through more than 76 foreign subsidiaries. The operation failure of Lehman Brothers was in complete secrecy, protected by apparently reliable ratings of 'A +' rating agencies, allowing time for Wall Street rid or minimize their risk positions.

On the other hand, the U.S. supervisory authorities had given a different precedent, to save 'in extremis' to Bear Stearns in March 2008, so we can say that the public received with disbelief and bewilderment huge statement Lehman insolvency.

Bankruptcy proceedings went to the Bankruptcy Court in Manhattan, just steps from Wall Street, where Judge James Peck has worked hard to complete one of the most profitable financial operations of the story, as an investment in legal fees related to the bankruptcy of 2.000 billion have been made to 'disappear' liabilities of Lehman Brothers over 400,000 million.

The 'disappearance' of that liability has had two parts: first, the reduction in the total amount of debt acknowledged, that initially stated totaling 465,000 million, but ultimately have fallen by about $ 360 million. On the other, a rebate of 82% on the debt finally recognized, ie expected final payment of about 65,000 million.

The return of 'Chapter 11' Lehman Brothers was therefore of 19.900%, a success that is no stranger to the excellence of the firm Alvarez & Marsal who took the reins of the administration of 'Chapter 11' most productive history. No wonder there is some surprise that recently, Judge Peck approved solicitous paying $ 26 million to the lawyers of Lehman creditors committee because he felt that it was "little money", but the representative of U.S. State objected to the proceedings on the ground that the payment has no place in the statute.

Lehman, the 'bad bank'

  
The U.S. bank Lehman was served as a 'bad bank' that 'put' 400,000 million in assets.

As mentioned, the impact on Europe of the bankruptcy was huge, because through its subsidiaries in London, Amsterdam and Luxembourg, the U.S. bank had placed thousands of million bond 'toxic' in the months before the declaration of insolvency, and to a lesser extent, also had placed around the world through its nearly 80 subsidiaries.

Actually, we can say that Lehman Brothers was the 'bad bank' system subprime U.S., through which U.S. banking could divest toxic assets 400,000 million by the 'simple' procedure place between investors, mainly from around the world.

For U.S. banks, the beneficial effects of the Lehman bankruptcy soon began to be noted: first, rival investment banks and then throughout the banking system, which has been obtained in 2012 the most benefit their entire history , surpassing the previous record of 2006. This, in part, achieved extraordinary sanitation through its 'bad bank', released by the collapse of Lehman Brothers more than four years prior to the 'bad bank' of the Spanish banking system. Notwithstanding this delay, the fact is that the management of our 'bad bank' will not be less than the 'Chapter 11' of Lehman Brothers in quality management, since the Ministry of Economy and Competitiveness precisely selected Alvarez & Marsal as Sareb manager.

Meanwhile, Lehman Brothers Holdings International has left the 'Chapter 11' with excess liquidity, not for less-, and to celebrate it has commissioned an international-after-the study of the architect Norman Foster, the design of its new and 'vibrant' corporate tower in New York, on Park Avenue (see previous page).
Similarly, the company has become a major U.S. real estate operators, after acquiring the remaining stake in Archstone for 1,580 million dollars, which also plans to bring to market soon.

The only sour note of the whole process seems to be that of its subsidiary in Switzerland, Lehman Brothers Finance AG, its parent claiming 15,400 million Swiss francs Judge Peck, to our knowledge, has not yet ruled on whether this figure seems little or a lot.

In the U.S. still hopes that successful beyond bankruptcy, Lehman case may have some legal persecution. Possible actions have been announced but has not materialized yet no. It had to be an Australian court has ruled that former, accusing management Lehman misleading and breach of contract. The time of President Lincoln seems remote: perhaps that is remembered now in a great movie.

And most importantly: thousands of savers affected, including those who were not fortunate enough to receive adequate repair offers from its banks at the time, had to wait-and hope-not recently, with great anguish, slowly, the courts of justice, in Spain, Italy, Germany ... - go pronouncing in favor of adequate demand for accountability to marketers. Entities that while they could not have a priori knowledge exact, though it had indirect enough to market their products-from what was 'cooking' on Wall Street, which is presumed self managed banks like Deutsche Bank, Citibank , UBS and BNP Paribas, in any case had a duty to be informed of all the risks sufficiently to their customers, even risking that no sign, and the inescapable duty loyal Had they been properly advised.

http://www.ausbancrevista.com/banca-reportaje/reportaje/2011-el-gran-negocio-de-lehman-brothers

Be careful. LBHI eventually could discharge all classes after POR. In fact, they are saying they will do - in the same POR- after satisfaction in full.

The guarantee is another subject. I can agree it seems strong enough to survive that discharge.

Lehman Swiss Deal Doubles Recoveries for Some Creditors

Joseph Checkler
April 19, 2013
(c) 2013 Dow Jones & Company, Inc.
Liquidators of the Swiss derivatives unit of Lehman Brothers Holdings Inc. said a recent settlement may double recoveries for the subsidiary's creditors.
In a Thursday filing with U.S. Bankruptcy Court in Manhattan, a partner at PricewaterhouseCoopers said the deal to resolve tens of billions of dollars in claims and counterclaims opens the door for better recoveries for creditors of Lehman Brothers Finance AG, already one of the better-treated groups in Lehman's historic creditor payback plan approved by a judge in late 2011.
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Nicholas Roberts
"The settlement agreement provides substantial economic benefit to LBF's creditors as it reflects significant concessions by LBHI made as a result of its own assessment of the litigation risks surrounding the claims," said the PWC partner, Christiana Suhr Brunner.
The resolution of the claims, filed with the court in early March, freed up dollars for those creditors that would have otherwise been going to others. Under the settlement, Lehman Brothers Holdings receives an approximately $10 billion claim against the Swiss unit. The Swiss unit will transfer $7.7 billion in claims that it had against various subsidiaries to the Lehman parent.
In return, LBF, the Swiss unit, will receive an allowed claim of $942 million against the Lehman parent. The holding company also agreed to have its claim treated as being lower on the totem pole than LBF's general unsecured creditors, who will receive an initial priority recovery of $1.275 billion.
The settlement, Ms. Suhr Brunner said, reduces Lehman's parent's claim against the Swiss unit so substantially that the Swiss creditors should now get about 60 cents on the dollar for their claims, up from about 30 cents.
The deal, if approved by a judge, will make several hedge-fund managers happy, including Paulson & Co . and Elliott Management. That's because while the Swiss fight was going on, $3 billion was held in reserve for the claim. Now, much of that money can go to other creditors like Paulson and Elliott.
Judge James Peck, who was critical of what he called the Swiss unit's "renegade" tactics to get better recoveries before the settlement, will consider whether to approve the deal at a hearing Wednesday.
Lehman Brothers Finance was based in Switzerland to take advantage of that country's less-taxing regulatory requirements. It was created to take hedge positions with respect to debt issued by other entities. The company didn't take in money and issue debt, making it different from other Lehman affiliates, according to its lawyers.
The holding company has already paid $47 billion back to creditors since its payback plan became effective last year.
Lehman collapsed in September 2008, becoming a symbol of one of the great financial crises in the country's history. Its U.S. brokerage business was quickly sold to Barclays , but the remnants of the rest of Lehman still exist in billions of dollars of assets being overseen by Alvarez & Marsal and the winding down of the brokerage business under the guidance of trustee James W. Giddens.
-Patrick Fitzgerald contributed to this article.

http://bankruptcynews.dowjones.com/article?an=DJFDBR0020130419e94jmzhru&r=wsjblog&ReturnUrl=http%3a%2f%2fbankruptcynews.dowjones.com%3a80%2farticle%3fan%3dDJFDBR0020130419e94jmzhru%26r%3dwsjblog

This point is under discussion yet.

The POR clearly says they eventually will discharge all classes after satisfaction in full. The question is if the guarantee is strong enough to survive that discharge. Cotton´s input about Euro subordinated notes suggests a new possible wayout for those guarantees.


13.4 Discharge. Except as expressly provided in the Plan, upon the date that all Distributions under the Plan have been made, (a) each holder (as well as any trustees and agents on behalf of each holder) of a Claim against or Equity Interest in a Debtor shall be deemed to have forever waived, released and discharged the Debtors, to the fullest extent permitted by section 1141 of the Bankruptcy Code, of and from any and all Claims, Equity Interests, rights and liabilities that arose prior to the Effective Date and (b) all such holders shall be forever precluded and enjoined, pursuant to section 524 of the Bankruptcy Code, from prosecuting or asserting any discharged Claim against or terminated Equity Interest in the Debtors.

We can take Class 4´s math like right. It si supported by Exhibit 14 in POR -agreement between LBHI and LBT about Lehman Notes- and the link I recent posted.

As Cotton mentioned, there are 5.8B on restricted cash, under the statement "Disputed unsecured claims". It could be a source of cash. I add the 2.2B priority tax claim with IRS, that not includes NOLs. I posted before the BS´s comments about it.

stockbum, I agree with those numbers. The more relevants are those related with Class 4A and 4B. As I mentioned before, class 4A represents Lehman notes of LBT and LBS, so it is a previous agreement, attached to POR. Idem with 4B and 5.

Anyway, LBI should close gaps and cancell the Plan, even with a remaining cash of 4/5B to add to real state equity. It will be enough to cancell preferreds if LBHI still think on liquidation.

With the % of distribution and the Wilmington report, we can only see a part of the cake. Maybe somebody remembers the docket related with a reduction on Class 3 Claims.

My point is we are close to a cancellation of POR, even with remaining distribution well above 3.8B. It is just chatter while we drink some coke...

You are probably right. I didn´t check Toogood numbers.

My previous math is supported by Class 3 of Wilmington Trust´s report after 3d distribution. Are these the only claims under Class 3?

Taking the 3d distribution and the numbers of Toogood´s post, the remaining distribution totalizes abt. 12B, only LBHI. It could be very possible the 14B coming from LBI agreement will cancel the plan next month.

Everything was already posted.

http://investorshub.advfn.com/boards/read_msg.aspx?message_id=81638791

Bankhaus claims are included under 4B, abt. 1B

http://www.sec.gov/Archives/edgar/data/806085/000119312511339839/d267202dex102.htm

Some DD about Class 4A, LBHI

Claims of LBT and LBS are under Class 4A- Senior Affiliate Claims, totalizing abt. 40.5B (34.5B and 6B respectively). I don´t know if it is the Total of the Class. The Plan estimates a recover of a 16.6% on this Sub-Class.

http://www.meteoram.com/uploads/files/Lehman_update_note_Oct_2011_for_advisers.pdf

In last distribution, the accumualted % is 11.668, so the pending distribution would be abt. 2B.

With these 2B and 3B pending under Class 3, we are actually above 5B adding only these classes. Im not taking into account the observation of Cotton about the restricted cash related with pending unsettled claims.

Nothing big happened so far.

They only paid 50B in a year, almost a 90% of estimated recovery in POR.
They did close an agreement with LBI and LBIE. They did recover only 2B to creditors and 15B to unsecured claims from the Trustee, to be distributed next month.
They signed an ageement with LBF, with an important claim in favor of LBHI.
A couple of thousand of claims were whithrawn.

What a waste of time.

That was my point since the beginning. I think Lehman is well above 3.8B of pending distribution, Remaning distribution on Class 3 - abt. a 6% - suggests that. But the pending money is coming from SIPA.

Cotton is right about some restricted cash to be distributed, actually on reserve for pending claims, but, imo, it is not included under POR, except they are settled below the prevision. jmho.

Is the announcement of possible pay in full to creditors of LBIE, related with LBI -LBIE agreement? The hearing to consider the motion by the Court was scheduled on April 16, 10:00am. They mentioned some recent agreement between affiliates in the PR.

The hearing to LBI-LBHI agreement was today too. Is a satisfaction in full POR´s announcement coming?

It was discussed a lot of times, it is true. But, besides your vehemence defending the point, it doesn´t mean it was already solved and it is a fact. I remember this paragraph about the subject, extracted from POR:

"The heading of this section reads “Section 1401. Junior Subordinated Debentures Subordinated to Senior Debt and Other Financial Obligations.” However, the first sentence of this definition states that the Junior Subordinated Debentures are subordinated to “all Junior Subordinated Debentures.” The Debtors believe that the reference to “all Junior Subordinated Debentures” was a typographical error and that the clear intent (as reflected in the definitive Junior Subordinated Debentures themselves) was to subordinate the Junior Subordinated Debentures to all Senior Debt."


"Unlike Section 1412 of Supplemental Indentures 9, 10, 13, 14, 15 and 16, Section 1412 of Supplemental Indentures 11 and 12 makes no reference to Other Financial Obligations, but provides that under certain circumstances the subordination in Section 14 will cease to apply to the Junior Subordinated Notes. For various reasons, the Debtors believe that this is a drafting error in the documents and that it was intended that the Junior Subordinated Debentures are subordinated to “Other Financial Obligations” to the same extent as in Supplemental Indentures 9, 10, 13, 14, 15 and 16 – i.e., that “Other Financial Obligations” are entitled to “Excess Proceeds” only after “Senior Debt has been paid in full. However, because Senior Debt will not be satisfied in full, and, thus, there will be no “Excess Proceeds,” “Other Financial Obligations” are not classified as senior claims by the Plan. Thus, whether the Junior Subordinated Notes are subordinated to “Other Financial Obligations” under Supplemental Indentures 11 and 12 is irrelevant."


The pari passu treatment of EU guarantees with preferreds is a clear signal imo, about the direction that LBHI took with the treatment of these guarantees. In fact, they mention in some paragraph all similar guarantees.

""LBHI’s Obligations Under the Subordinated Guarantees are Subordinated to All Liabilities of LBHI and Equivalent with Preferred Equity of LBHI" Page 3 on document posted by Cotton.

I make an additional comment about the paragraph. It seems that LBHI put in similar terms "paid in full" and "satisfied in full". Is it a typographical mistake? mmm, there are too many doubts to be so sure right now.

Reading this board, it seems there is a consensus about it is not over, that there are enough assets to keep Lehman running.

Exception...Cotton is right - and I believe he is - about the asumption that CTs will be included in OBS on parity with preferreds. Then, even with liquidation, it is possible to see some money coming from remaining illiquid assets.

"all cumulative dividend arrearages must be paid in full if the BHC is to continue to operate as a going concern."

This is the key factor and we did discuss it a lot of times. Is Lehman going to continue to operate as a going concern or is it a liquidation? CTs´s fate is in the answer of this question.

Im not sure how much we can count on this. Only 400M are distributions not remitted. There are 5.8B on disputed unsecured claims, are you adding this? Thanks

You have a good point with that. I have a doubt about the SIPA money to be released on April 24. Shouldn´t that money close the gap of pending debt under POR? Even with some discrepancy about the pending debt - The Wilmington trust report suggests the pending distribution is bigger than 3B - I think the Trustee´s money to be paid to unsecured claims should close the gap. What do you think? Otherwise, if they used that money under some accounting trick, they should have available 10B of free cash, We will see on next MORs.

I believe the difference probably comes from distribution to creditors and affiliates. I saw some distributions to LBT under their agreement about Lehman notes - 34B unsecured claim-

In last distribution, they reported 10B to creditors and 4.4 between controlled affiliates.

There are some enlightening posts from Cotton about this subject. I resume it in a phrase "Take it or leave us liquidate at present values, without the support of our staff of employees, with a lot of pending bonuses and RSUs"

I haven´t got available the total amounts related with CLASS 4A, 4B and 5.

Estimated recovery under POR
4A 15.6% Accumulated 11.668%
4B 15.2% " 13.399%
5 12.2% " 9,12%
6A 26% " 26% (1)
6B 17% " 17% (1)
7 19,9% 13.888%
8 14.4% 10.74%
9A 11.5% 8.59%
9B 7% 5.22%

(1) They didn´t receive money on 2d and 3d distribution. Satisfied in full.

Could somebody help me with this? Im trying to rebuild the pending distribution, but analyzed from every class´s point of view .

I was checking Class 3.- Unsecured Claims, most of them (or a 100%?), under Willmington Trust. In its last recent report,

http://www.wilmingtontrust.com/lehman/pdf/03_27_13_Lehman_Notice.pdf

I see,

Debtors expect that Class 3 claimants will recover 21.1% under POR. They received, in last distribution, 4.973258% or 2.431B. Accumulated, they received a 14.811672%, so, the pending sum would be abt. a 6.29%. It is abt, 3B pending.

So. it means that 3.8B as remaining amount to be paid seems short. I think there will be available 14B coming from SIPA, but is it possible to estimate the pending amounts in the heaviest classes, to rebuild the pending distribution?

LBT notes are the biggest claim in BS. Note 9, page 11 on BS report

Besides the counterpoint if 10B company is big enough to deserves a fenix´s destiny, lol, did somebody read LBT´s article?

It ends saying..

"As distributions from LBHI estate are expected to be recieved by the LBT estate for at least the next four years. It will take another four years before the liquidation of LBT is fully completed". Comments are welcome.

My reading was LBI was paying to creditors of LBHI 14B on unsecured claims and 2B on secured claims. Thats the agreement if I did understand it properly. They must be transferring that money to creditors accounts after court approval on April 26.-

The objection related with German unit is related with a previous agreement between LBHI and Bankhaus for 6B.

"Lehman Brothers Holdings, the parent, struck its own $6.6 billion settlement with Bankhaus in early 2011 that settled all intercompany squabbles between the parties, but didn't involve Mr. Giddens." (LBI)

http://www.foxbusiness.com/news/2013/04/08/lehman-parent-disputes-brokerage-settlement-with-german-unit/#ixzz2PywAcnJL

LBT

https://docs.google.com/viewer?a=v&q=cache:Pbj9RiDKlaMJ:www.srz.com/files/News/c055946f-a36b-4540-9765-8a16fa4bb393/Presentation/NewsAttachment/195898d2-e530-4188-bd53-9699e30181d5/040313_First_Distribution_Expected_in_Dutch_Bankruptcy_of_Lehman_Brothers_Treasury_Co_BV.pdf+LBI+25B+TRUSTEE+LBHI&hl=en&pid=bl&srcid=ADGEEShfUA9hh3PUIIxq1nY-x0qQaSER007Gu_sHamMTb-VK_hSmPyr97R5yCoGao-mVEqbSosUSze3hwCKa8nqxRh3cwiQf1aGQotif09x6PQpU-QQ9C9g8g3vW8frp2ydT5ySQhFuq&sig=AHIEtbRctcREV_1oDyQlR5cyalB9wuVt-g

It won´t help imo. The agreement between LBI and LBHI is a closed deal. Except ! that LBI and LBF have pending claims. I don`t know.

After being a 600B company, a new Lehman of 10B is a joke- Under this reorganization, they were liquidating every core business under its umbrella: real state gem, commercial bank unit, derivatives, etc. The size of remaining assets is a key factor imo, to see if they are looking for a new company or not. It seems they have enough hidden assets to survive, but every step suggests another thing. It is just an opinion.

I add a comment. If you are right about that only 10/15B are the remaining assets after the POR, Im sure it is a Liquidation. Only if remaining assets are well above 25B mark, as Togood did sugest a lot of times, it could be a reorganization looking for a new company. jmho.-

Chapter 11 Liquidations

The Bankruptcy Code's ultimate goal as it relates to businesses is to maximize value for creditors. In recent months liquidations, as opposed to reorganizations or going concern sales, have become a common method of achieving this goal. Indeed, even in cases where a substantial portion of the business is sold, the ultimate value to general, unsecured creditors is often derived from the liquidation of other assets.

While chapter 11 of the Bankruptcy Code is entitled "Reorganization," it is well settled that chapter 11 may be used to facilitate the orderly liquidation of assets. Companies often use chapter 11 to liquidate their assets because management remains in place during the bankruptcy process. Some argue that this results in a more orderly liquidation that increases the ultimate return to creditors.

Many recently filed chapter 11 cases, which presumably began as intended reorganizations, have become going-out-of-business liquidations shortly after filing. Often, the need to liquidate results from a lack of liquidity and increased administrative costs associated with a bankruptcy filing following the enactment of the Bankruptcy Reform Act of 2005 (BAPCPA). In particular, the highest priority (referred to as "administrative status") has been granted to parties that deliver goods to a debtor within 20 days of the bankruptcy filing and appears to have made reorganization more difficult. Such claims must now be paid in full in order to confirm a reorganization plan, whereas prior to BAPCPA, these claims were paid in the same manner as general unsecured claims. In addition, as a result of BAPCPA, bankrupt companies must determine whether to assume or reject their leases much earlier than under prior practice, and have a shorter time period during which they have the exclusive right to confirm a plan of reorganization.

Further, the tightening credit market has made debtor-in-possession financing more difficult. By the time a company files for bankruptcy relief, it is often unable to operate using "cash collateral" and must rely upon financing to complete the bankruptcy process. Where such financing is available, it is often subject to shortened terms, high fees and high rates of interest. Such terms result in pressure on a debtor to quickly obtain cash to satisfy the debtor-in-possession loan rather than the necessary breathing space for a going concern sale or reorganization.

Moreover, the longer a company takes to reorganize, the greater the administrative expenses that must be satisfied prior to a return to general unsecured creditors. In many ways, liquidating a business is simpler and quicker than attempting to make the necessary operational changes and to restructure the many obligations that modern companies have on their balance sheets. Rather than allowing the company the time it would need to restructure, secured and unsecured creditors appear to desire certainty. The pressure to liquidate appears most widespread in the retail sector, where reorganization is especially difficult. Famous retail brands such as Circuit City, Whitehall Jewelers, Linens 'n Things, Friedman's Inc., The Sharper Image, Boscov's, Mervyn's, Steve & Barry's and Bombay Company have all recently liquidated in bankruptcy. Most of these retailers began the bankruptcy process with the hope of reorganizing or selling some stores as going concerns, but were quickly forced to liquidate.

In retail bankruptcy cases, liquidations are typically accompanied by going-out-of-business (GOB) sales. Most often, these sales are administered by an "agent" hired by the debtor that guarantees the estate a certain percentage of the cost value of the debtor's inventory, with a higher recovery possible depending upon the ultimate results of the sales. Several companies may bid at auction for the right to be the debtor's GOB agent. The liquidator typically prices products close to retail at the start of a GOB sale, with prices reduced periodically throughout the sale term until all the inventory is sold. In some cases, liquidators are permitted to "augment" the existing store inventory with other goods. Once the GOB sales are completed, retail debtors in liquidation will typically auction leases and sell any remaining assets, including intellectual property.

Once the assets of a business are substantially liquidated, either the debtor or the creditor's committee will typically propose a plan in order to make distributions to creditors. A chapter 11 liquidating plan often includes provisions for the establishment of liquidating or litigation trusts that will bring causes of action on behalf of the estate. Chapter 11 liquidating plans must be confirmed pursuant to the requirements of § 1123 and 1129 of the Bankruptcy Code. Among the requirements for confirmation of a plan is that administrative priority creditors be paid in full. In the event that insufficient funds exist to pay administrative creditors, the case is referred to as being "administratively insolvent." Administratively insolvent cases are typically converted to chapter 7.

http://www.metrocorpcounsel.com/articles/11228/liquidation-troubled-businesses-chapter-11-liquidations-increasing

Can LBHI eventually satisfy POR and delay the discharge? It would be a way of preserving NOLs..