The lawyer that wrote it feels that his primary responsibility is to the first people in line. They have the most chance of recovery. That's what he's laying it on the line for. And all the things like NOLs and other matters unresolved, don't figure in his plans.
He seems to be looking at a negotiation for settlement with the FDIC and JPM that just addresses the first people in line and kills the company.
It's an informative document. But he seems to be saying in some places that because the common equity has such a slim chance, that all equity should be denied representation. Or that it it already represented adequately.
He's playing to "his people", the creditors. It would be JOY to see his motion get stuffed.