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Re: investsen post# 2131

Tuesday, 11/10/2020 12:36:07 PM

Tuesday, November 10, 2020 12:36:07 PM

Post# of 2604
FNBCQ Equity_Interests (Common_Stock) ARE_NOT_IMPAIRED under_the_Plan! woot_woot!

"The following Classes are not impaired under the Plan: Class 7 – Equity Interests (Common Stock).
FNBCQ Through this motion, Plan Proponents seek a 58-day extension of the deadline (or until
November 11, 2020) for the Effective Date to allow: (1) the First Round Investors to conclude
their assessment of any effects of the Appeal on future business operations of the Debtor; and/or,
(2) the District Court to rule on the Motion to Dismiss the Appeal. In addition, they assert that the
extension requested is reasonable given the delay between commencement of this Chapter 11 Case
in May 2017 and the Confirmation Date of May 15, 2020. In connection with the foregoing request, the Plan Proponents seek this Court’s approval
to amend the FRI Escrow Agreement to provide for the balance of the First Round Investment to
be deposited into the Escrow Account on or before November 4, 2020. Based on the post-confirmation developments, resulting uncertainties existing in this case
and the time needed to resolve such uncertainties, Plan Proponents respectfully request that this
Court approve an extension of the Effective Date deadline for the Joint Plan until November 11,
2020 and the deadline for the First Round Investment funding until November 4, 2020."

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