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Re: None

Monday, 07/19/2021 2:35:32 PM

Monday, July 19, 2021 2:35:32 PM

Post# of 311
Because of the Debtors right of exclusivity their plan is before the court for its consideration to be solicited.

The OCUC, in the hopes of and anticipation of the Debtors right of exclusivity being terminated has prepared and presented the court its POL. And if allowed to be solicited is asking that the court either reject the Debtors plan altogether or allow both plans to be presented in order to have a head to head vote decide the winning plan.

Debtors 2nd Plan put out 7/6/2021;

Class 1 Secured Claims Unimpaired; Not Entitled to Vote (Presumed to Accept) Approx. $0 Recovery: 100%

Class 2 Priority NonTax Claims Unimpaired; Not Entitled to Vote (Presumed to Accept) Approx. $1,680.67 Recovery: 100%

Class 3 Notes Claims Impaired; Entitled to Vote Approx. $125,506,108.33 Estimated Recovery:

Class 4 General Unsecured Claims Impaired; Entitled to Vote Approx. $7.2 million Estimated Recovery:

Class 5 Intercompany Claims Unimpaired / Impaired; Not Entitled to Vote (Presumed to Accept or Deemed to Reject)

Class 6 Interests Impaired; Entitled to Vote (Presumed to TBD Estimated Recovery: N/A Recovery: $0 Accept)

--------------------------------------

OCUC POL Treatment

Class 1 Secured Claims Unimpaired Not Entitled to Vote (Presumed to Accept)

Class 2 Other Priority Claims Unimpaired Not Entitled to Vote (Presumed to Accept)

Class 3 General Unsecured Claims Impaired Entitled to Vote

Class 4 Intercompany Claims Unimpaired / Impaired Not Entitled to Vote (Presumed to Accept or Deemed to Reject)

Class 5 Interests Impaired Not Entitled to Vote (Presumed to Reject)

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It appears one of the main decisions the court must decide is simply who votes and who doesn't.

Marker:

MDLXQ - currently at $0.40 @ share
MDLQQ - currently at $0.42 @ share






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