Sears Holdings Corp. (fka SHLDQ)

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C. The Debtors have Demonstrated Reasonable Prospects for Filing a Viable Plan.

30. The first phase of these chapter 11 cases have centered on stabilizing the Debtors’ businesses and pursuing the sale process. The Debtors have commenced formulation of a chapter 11 plan and are evaluating the contours of a potential plan including the Debtors’ significant tax attributes. The Debtors are currently highly focused on the sale process, following which the Debtors will engage in discussions with their stakeholders on the terms of a chapter 11 plan. The Debtors are prepared to quickly proceed with the plan negotiation, solicitation and confirmation process. Given the Debtors’ track record to date in these cases and the achievements summarized above, the Debtors have demonstrated reasonable prospects for filing a viable chapter 11 plan.