AICI Capital Trust 9% Pfd (fka AICPQ)

[Enterprising Investor]

Objection / Joinder and Supplemental Objection of Deutsche Bank Trust Company Americas, as Trustee, to Objections of Debtor and Official Committee of Unsecured Creditors to Disclosure Statement of Granite Reinsurance Company Dated February 9, 2009 Filed by Creditor Deutsche Bank Trust Company Americas (3/02/2009)

The Disclosure Statement is grossly deficient and must be rejected. As is fully set forth in the objection filed by the Debtor (the “Debtor Objection”) and the objection filed by the Committee (the “Committee Objection”), the Disclosure Statement (i) does not contain adequate information to enable the Public Holders (defined below) to make an informed judgment about the Plan, (ii) is inconsistent with the Plan, and (iii) relates to a plan that is patently unconfirmable. In addition to the issues raised in the Debtor Objection and the Committee Objection, the Plan violates Sections 510(a) and 1123(a)(5) of title 11 of the United States Code (the “Bankruptcy Code”) and thus cannot satisfy the requirements for confirmation specified in Sections 1129(a)(1) and (3) of the Bankruptcy Code. Furthermore, there appears to be no valid justification for separately classifying the claims of the Public Holders in respect of the Debentures (defined below) as not a single creditor has been identified whose claim constitutes Senior Indebtedness (as efined in the Indenture (defined below)). As such, the Plan violates Section 1122(a) of the Bankruptcy Code in an attempt to gerrymander an impaired accepting class for purposes of satisfying the requirements of Section 1129(a)(10) of the Bankruptcy Code. In light of the foregoing, and as set forth in greater detail below, approval of the Disclosure Statement must be denied.

Source: PACER [Docket 401]