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Re: None

Friday, 07/22/2011 9:12:17 AM

Friday, July 22, 2011 9:12:17 AM

Post# of 19456
TDLPQ NEW PLAN OF REORGANIZATION COMMONS ARE SAFE
Outstanding!! Per the filed case (dated July 11, 2011): http://ia700607.us.archive.org/33/items/gov.uscourts.casb.348892/gov.uscourts.casb.348892.20.0.pdf

EXCERPTS:
"DermaStar and Ladonnikov are Prepared to Negotiate and Fund a
Plan of Reorganization with the Debtor.
In contrast to the Sale Motion, which strips the estate of any upside of the
successful commercialization of its product and yet subjects the estate to considerable
risk, DermaStar and Ladonnikov (collectively, the “Plan Sponsors”) are prepared to
negotiate and, if an agreement can be reached, fund a plan of reorganization which will
allow the Debtor’s creditors and shareholders to realize immediate and future dividends.
In short, the Plan Sponsors are prepared to provide immediate funds to pay administrative
expenses and a portion of the Debtor’s unsecured claims on confirmation; sufficient
operating capital to complete the second Phase 3 trial; an experienced board and
management team to oversee the final Phase 3 trial and, if approved, bring the product to
market; and a commitment to bring the product to market. The Plan Sponsors, which
include the Debtor’s largest unsecured creditor, believe that a plan of reorganization will
yield a greater recovery for the Debtor’s creditors and shareholders without the additional
risk of significant losses from Cardium’s business lines
with significant historical losses.


CONCLUSION
For the foregoing reasons, Ladonnikov and DermaStar respectfully request that the
Court either (1) deny the Sale Motion; or (2) deny the break-up fee and continue the
hearing on the Sale Motion for 20 days to allow the Debtor and the Plan Sponsors to
engage in negotiations to determine if a confirmable plan of reorganization can be
proposed.
DATE: JULY 11, 2011 FOLEY & LARDNER LLP
VICTOR A. VILAPLANA
MATTHEW J. RIOPELLE
BY: /S/ MATTHEW J. RIOPELLE
MATTHEW J. RIOPELLE
ATTORNEYS FOR ALEXEJ LADONNIKOV
AND DERMASTAR INTERNATIONAL, LLC"
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