Relief Requested
By this Motion, the Debtors seek entry of interim and final orders (a) establishing
notice and objection procedures regarding certain transfers of beneficial interests in equity
securities in HoldCo, (b) establishing a record date (the “Record Date”) for notice and potential
sell-down procedures for trading in claims against the Debtors (“Claims”), and (c) granting
related relief. The relief requested in this Motion is necessary to protect the potential value of
the Debtors’ net operating losses (“NOLs”)
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