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cottonisking

10/05/25 10:12 AM

#115009 RE: cottonisking #115008

Motion to Extend Plan Trust:

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part because of their subject matter expertise in the major asset categories of the Debtors’ then-
vast estates and subsidiaries along with restructuring and financial management experience.
7. Since the Effective Date, the Plan Trust and the Board of Directors have
overseen the Plan Administrator’s active management and achievement of major milestones
towards the liquidation of the Debtors’ estates, including:
• the wind down and monetization of the Debtors’ vast global asset portfolios, comprised of
private equity, real estate, loans, derivatives, non-controlled affiliate assets, intra-debtor
claims, and other positions; and the disposition or dissolution of more than 2,000 controlled
non-debtor subsidiaries;
o only a handful of private equity/principal investments and a single active derivative
trade, set to terminate in 2025, remain;
• 30 Distributions totaling more than $96 billion on account of third parties’ claims,
approximately $40 billion more than the Debtors had estimated (subject to various
disclosures and assumptions) prior to Plan confirmation;
o ten of the Debtors distributed recoveries of 100% (or more with post-petition
interest) to their general unsecured creditors [see ECF 61769];
o general unsecured creditors of two other Debtors with guarantee claims against
LBHI received recoveries of 100% or more [id.];
o general unsecured creditors of LBHI have received approximately 46.7% on account
of their Senior Unsecured claims [id., ECF 61769];
• the resolution of nearly 70,000 claims (totaling in excess of $1.2 trillion) asserted in these
chapter 11 cases, allowing 45,000 of these claims at a reduced value of approximately $316
billion;
• the closure of 22 of the 23 chapter 11 cases, leaving only LBHI’s open; and
• the reduction and simplification of the LBHI creditor base through two court-approved
programs (from over 25,000 creditors with approximately 40,000 claims on the Effective
Date to approximately 900 creditors with over 7,000 Allowed Claims remaining today).3
3
Claims for publicly-traded securities where Plan Distributions flow to indenture trustees or
similar intermediaries where LBHI makes single distributions that are subsequently more widely
dispersed are counted as one.
08-13555-mg Doc 61844 Filed 09/12/25 Entered 09/12/25 16:16:42 Main Document
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