Compromise and Settlement of Claims, Interests, and Controversies
Pursuant to section 1123 of the Bankruptcy Code and Bankruptcy Rule 9019 and in consideration for the
distributions and other benefits provided pursuant to the Plan, the Plan is and shall be deemed a good-faith compromise
and settlement of all Claims, Interests, and controversies relating to the contractual, legal, and subordination rights
that a holder of a Claim or Interest may have with respect to any Allowed Claim or Interest, or any distribution to be
made on account of such Allowed Claim or Interest.
The entry of the Confirmation Order shall constitute the Bankruptcy Court’s approval of the compromise or
settlement of all such Claims, Interests, and controversies, as well as a finding by the Bankruptcy Court that such
compromise or settlement is in the best interests of the Debtors, their Estates, and holders of Claims and Interests and
is fair, equitable, and reasonable. The compromises, settlements, and releases described herein shall be deemed
nonseverable from each other and from all other terms of the Plan. In accordance with the provisions of the Plan, pursuant to Bankruptcy Rule 9019, without any further notice to or action, order, or approval of the Bankruptcy Court,
after the Effective Date, the Reorganized Debtors, may compromise and settle Claims against, and Interests in, the
Debtors and their Estates and Causes of Action against other Entities.
