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Monday, November 19, 2018 5:23:51 PM
"Additionally, at such time, it was discussed that entry of an order with respect to the undisputed items would be deferred. However, as discussed below, due to the undisputed nature of such items, as well as the desire to provide distributions with respect thereto to holders of allowed claims, WMILT is hopeful that the Court would reconsider its prior position. This is especially so, as the Claimants have expressed an intention to appeal from any order and it would be in the creditors' interest to commence that process."
"However, WMILT believes that entry of the Revised Proposed Order is necessary to ensure that there is not a further deterioration to recoveries for other creditors due to not making distributions to holders of allowed claims and thus permitting additional interest to accrue on their claims and diminishing or eliminating the recoveries which may be made to creditors lower in the waterfall."
"WHEREFORE, WMILT respectfully requests that the Court enter the Revised Proposed Order at its earliest convenience."
"4. In light of the remaining questions of fact and/or law that were discussed on the
record at the Order Hearing, the following components of Claims shall not be deemed disallowed at this time (the “Surviving Claims”): Surviving claims are the ETRIP, SERAP
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