The Plan Administrator has published balance sheets and estimates of future cash flows for the Debtors since the Effective Date. It filed the most current balance sheets and estimates of future Distributions (by Eligible Class) contemporaneously with this Motion. See ECF No. 61142 (Quarterly Financial Report as of April 1, 2021 (Unaudited) (the “Q1 2021 Financial Report”)). Three takeaways from the Plan Administrator’s public reporting are important to highlight. First, the Plan Administrator estimates that its liquidation of LBHI’s remaining assets will yield, over time, additional Distributions of approximately $1.1 billion, subject to various important notes, caveats, and considerations disclosed in the Q1 2021
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Financial Report.3 Second, the Plan Administrator’s estimate of LBHI’s remaining assets is approximately 1.0% of LBHI’s Distributions to third parties to date. This estimate will yield additional Distributions of between 0.459% to 0.699% of the Allowed amount of Claims in the Eligible Classes, subject to the same notes, caveats, and considerations.4 Third, even at this late stage, the timing of LBHI’s ultimate liquidation and the ultimate remaining amount available for Distribution cannot be determined with precision; both depend primarily on the inherently- uncertain resolution of various significant litigations in oth
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