Brief Summary of the Combined Disclosure Statement and Plan
The Combined Disclosure Statement and Plan is premised upon maximizing the remaining
value of the Debtor’s assets. Specifically, the Debtor has three primary assets: (i) cash on hand,
(ii) income stream generated from the Remaining Company Contracts, less the costs of operations,
and (iii) Causes of Action, including potential claims against certain current and former Insiders.
On the Effective Date, the Liquidating Trust will be established for the benefit of creditors holding
Allowed Claims, and the Debtor will transfer all cash on hand and the right to the Causes of Action,
including the net proceeds from the Causes of Action, all of which will be vested in and retained
by the Liquidating Trust. Additionally, on the Effective Date, the Debtor will transfer its right to
all equity distributions from its non-Debtor subsidiaries which result from the non-Debtors’
continued performance under the Remaining Company Contracts, and such right will vest and be
retained by the Liquidating Trust. All distributions on account of Allowed Claims will be paid
from the Liquidating Trust, which shall be funded on the Effective Date from the Debtor’s cash
on hand.
Twitter: @VincePagano
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