Certain additional Claims either are or could be classified in Class 18, but are disputed on the basis of, among other things, validity, amount, and/or appropriate classification. For example, pursuant to that certain Stipulation Resolving Debtors’ Amended Thirty-Second Omnibus (Substantive) Objection With Respect to Claim Nos. 3812 and 2689 [D.I. 6068], dated November 23, 2010, by and among, among others, the Debtors and the Policeman’s Annuity and Benefit Fund of the City of Chicago (defined in Section V.B.6.g below as “Chicago PABF”) and Doral BankPuerto Rico (defined below as “Doral Bank”), as lead plaintiffs, on behalf of a putative class, in the consolidated putative securities class action entitled Boilermakers National Annuity Trust Fund v. WAMU Mortgage Pass Through Certificates Series ARI, Case No. 09-0037 (MJP) (the “Boilermakers Plaintiffs”), the parties thereto agreed that certain Claims filed by and on behalf of the Boilermakers Plaintiffs would be withdrawn, without prejudice to the re-filing of such Claims in the event that a plan was filed that would provide recovery to holders of Allowed Subordinated Claims. Certain Boilermaker Plaintiffs argue that they are now permitted to refile their Claims because the Seventh Amended Plan provides for a conditional distribution to holders of Allowed Subordinated Claims. In the Boilermaker Plaintiffs’ objection to this Disclosure Statement [D.I. 9316], filed January 4, 2012, the Boilermaker Plaintiffs asserted that they are entitled to re-file their Claims as General Unsecured Claims rather than as Subordinated Claims. On January 10, 2012 the Boilermakers Plaintiffs submitted a new proof of Claim, asserted in the amount of “at least $273 million,” on behalf of the putative securities litigation class. The Debtors dispute this Claim, and, as of the date of this Disclosure Statement, no party has moved to estimate such Claim
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