My thought is that if this argument is true, then the conversion to equity is co-terminus with Wamu (e.g., sure, you'd get equity 30 days after the conversion, but equity gets $0, so you get nothing).
But the filing today takes the cake. In many respects, it completely undercuts any logic to the court granting a motion for summary judgment (because the filing contains a ton of factual assertions that a court would ordinarily decide at trial).
I just don't understand the thinking. But my suspicion is that Wamu is going "all in" to get the POR approved, and this is part of that. But talk about straining your credibility.