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Friday, 07/08/2016 4:49:09 PM

Friday, July 08, 2016 4:49:09 PM

Post# of 4800
"unsecured creditors are the fulcrum class"

DOCKET 247

http://www.cnbc.com/id/32657993

DOCKET 247

"2. There is no serious question that unsecured creditors are the fulcrum class in these
cases. Oil prices have been rising, and with them, the Debtors’ enterprise value. The value of
the Debtors’ portfolio of properties in the Permian Basin alone has doubled since December, as
demonstrated by recent transactions involving comparable assets.
3
It would not be difficult for
the Debtors to establish that the Prepetition Secured Parties are oversecured, and so are already
protected from any diminution in the value of their collateral.
3. Notwithstanding this “equity cushion,” the Debtors seek to provide even more
protection to the Prepetition Secured Parties in the form of new liens on all of the Debtors’ assets
– including “$50 million in total value” that the Debtors have conceded was not subject to any
perfected security interest as of the petition date. Tr. 5/16/2016, at 11. The proposed order then
would use the grant of these new security interests to justify imposing restraints on the
Committee’s investigation of claims against secured creditors. "
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