ATPG Senior 11.875% 2nd Lien Bonds (fka ATPG.GE)

[romang]

http://www.kccllc.net/documents/1236187/1236187130619000000000010.pdf


And the Debtor is proposing to give the DIP Lenders even more
value not reflected in these reports in the form of rights to significant litigation claims that are
not subject to the DIP Lenders’ liens and intercompany Claims and equity interests in the
Debtor’s subsidiaries that are currently property of the estate. Moreover, neither the litigation
rights nor the subsidiary equity interests were ever marketed to third parties, having been listed
Case 12-36187 Document 2058 Filed in TXSB on 06/19/13 Page 5 of 20
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as “Excluded Assets” under the form asset purchase agreement provided as an exhibit to the Sale
Motion.