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Replies to post #540709 on Mr Cooper Group Inc fka COOP
EXHIBIT B
FORM OF PROPOSED ORDER
ORDER
(I) GRANTING WMI LIQUIDATING TRUST’S OMNIBUS OBJECTIONS,
(II) DEEMING THE CLAIMANTS’ CLAIMS DISALLOWED,
(III) AUTHORIZING THE DISTRIBUTION OF FUNDS IN THE DISPUTED CLAIMS RESERVE, AND
(IV) DISMISSING THE WMI LIQUIDATING TRUST’S ADVERSARY PROCEEDINGS Upon the motion, dated August 30, 2018 (the “Motion”), of WMI Liquidating Trust (“WMILT” or the “Trust”), as successor in interest to Washington Mutual, Inc. and WMI Investment Corp., formerly debtors and debtors in possession (collectively, the “Debtors”), for the entry of an order (this “Order”)
(i) granting WMILT’s Omnibus Objections,
(ii) deeming the Claims disallowed,
(iii) authorizing WMILT’s distribution of cash and Liquidating Trust Interests in the Disputed Claims Reserve on behalf of the Claims, and
(iv) dismissing the WMILT’s Adversary Proceedings against the Claimants, all as set forth in more detail in the Motion; and due and proper notice of the Motion having been provided to those parties identified therein, and no other or further notice being required; and the Court having held a hearing, if necessary (the “Hearing”), with respect to the Motion and the relief requested therein; and the Court having determined that the relief sought in the Motion is in the best interests of WMILT, the Debtors’ creditors, and all parties in interest; and the Court having determined that the legal and factual bases set forth in the Motion establish just cause for the relief granted herein; and after due deliberation and sufficient cause appearing therefor,
IT IS HEREBY ORDERED that:
1. The Omnibus Objections are granted with respect to the Claimants, as set forth herein.
2. Each of the Claims is hereby deemed disallowed in its entirety.
3. Kurtzman Carson Consultants, LLC, WMILT’s court-appointed claims and noticing agent, is authorized and directed to delete the Claims from the official claims register in the Debtors’ chapter 11 cases and take any other actions necessary to implement the relief granted herein.
4. WMILT is authorized to release and distribute such cash and Liquidating Trust Interests held in the Disputed Claims Reserve on behalf of the Claims in accordance with the provisions of the Plan.
5. Upon this Order becoming a final order, (a) the Adversary Proceedings shall be deemed dismissed with prejudice and (b) the Clerk of the Court shall be directed to enter this Order on each of the dockets in the Adversary Proceedings.
6. WMILT is authorized to take any actions necessary to implement the relief granted herein.
7. This Court shall retain jurisdiction to hear and determine all matters arising from or related to the implementation, interpretation, or enforcement of this Order.
AI
