Mr Cooper Group Inc (COOP)

[ron_66271]

“griffins tantrum”

18. Griffin’s assertion that WMILT should not have entered into the March 2013 Stipulation because “one doesn’t pay something for nothing,” is misguided. Griffin ignores the fact that the Underwriters and WMILT agreed that the Underwriters held valid Class 19 Claims against the Debtors. Moreover, although the Underwriters asserted that they also had valid Class 18 Claims against the Debtors, the Underwriters agreed to have their Class 18 Claims, in the amount of approximately $24 million, which would have been senior in right of recovery to holders in Classes 19, 21 and 22, disallowed in their entirety.

19. Moreover, the Underwriters did not receive a windfall on account of the allowance of their Class 19 Claims. In fact, they received the distribution applicable to their Class 19 Claims, which turned out to be a nominal percentage distribution of the common stock of Reorganized WMI. The value of the Reorganized Debtors’ equity interests distributed pursuant to the March 2013 Stipulation was, as of the time the equity interests were issued, approximately $1.1 million.

20. Finally, Griffin erroneously claims that the existence of the March 2013 Stipulation was not disclosed for at least a year. In fact, WMILT disclosed the existence and terms of the March 2013 Stipulation in its 2012 10-K filed on April 1, 2013, mere days after the March 2013 Stipulation was executed.

21. Accordingly, for the reasons stated herein and in the WMILT Response, the Griffin Objection should be dismissed or, if considered, denied in its entirety. (FN 5)