JCPNQ CR3 Snyder Report - Couple of Facts
23. Reorganization and material cash balances clearly demonstrate an ability of the Debtors to pay their obligations to creditors in the ordinary course of business, with no additional capital required.
24. Further, it is my opinion that the transaction the Debtors are proposing materially undervalues the assets, as illustrated in our report and herein, and will not provide a recovery to any creditor class above the First Lien Lenders.
Conversely, a reorganization under chapter 11 is plausible, and definitively provides a return to all classes of creditors, and likely to shareholders as well.
I declare under penalty of perjury that the foregoing is true and correct.
Dated: October 28, 2020
