It appears that the Debtor has about $100M of variance from the lowest amount the DIMEQ LTWs believe that they are entitled to "prior to added damages and prior to interest."
I have a worksheet that is my attempt to first calculate the conversion feature {which would be a real poison pill if the Examiner brings commons into the money, staggering dilution}, then calculate the cash settlement.
I used a range approach, all taxes paid at 46%+ per the LTW agreement "regardless of actual rate" also as per the agreement; and no taxes paid. The purpose was to show the level that is available to the parties work it out.
I've never had anyone check the analysis so I'd be interested in any corrections that are noted.