SandRidge Energy, Inc. (fka SDOCQ)

[Don'tDrinkTheKoolAid]

PG 16:
4. Only two Objections remain outstanding. The Shareholder Group asserts that the Plan is unconfirmable because it cancels prepetition common stock without a recovery. Yet, surprisingly, the Shareholders Group’s own expert asserts a high-end valuation—ranging between an asserted $3 and $4 billion—that would not justify a recovery beyond the Debtors’ $4.1 billion in funded debt. Whether this was an oversight or not, the Court may deny the
Objection on this basis alone. Nonetheless, the Debtors will present evidence at trial that common stock is “out of the money” by not just millions but, rather, billions of dollars.

5. The other Objection comes from FSISD, a Pecos County school district that forwent its state law rights to challenge tax appraisals for over a decade and now asserts that the Plan cannot be confirmed because of an alleged $500 million tax claim. But the state law period for FSISD to challenge ad valorem taxes has expired, and FSISD has not alleged, nor can it Case 16-32488 Document 845 Filed in TXSB on 09/03/16 Page 12 of 613 demonstrate, any facts in support of its claims, including its baseless allegations of fraud. These Objections fail as a matter of a law and fact.
6. The Debtors worked with the other parties in interest that raised formal and informal Objections and have resolved each of these. As a result, and for the reasons set forth more fully in this brief and at the hearing on confirmation, the Court should confirm the Plan.