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NY73

02/02/11 9:00 AM

#2839 RE: bepop12345 #2838

In reading the original proposed order carefully, it's interesting to note that the order covers the payment of administrative claims for a total of around $500k, which is over an $800k reduction in the claimed amounts, and the 'reorganization' anticipates paying out the rest of the cash remaining to unsecured creditors. A BK lawyer would be very helpful here to explain what this indicates. I would like to think it means a clean slate for the reorganized company, with no creditors other than shareholders and Liberty.

12. The Settlements and Mutual Releases between the Debtors and various
Administrative creditors meet all of the above criteria. By settling various Administrative
Claims, the Debtors believe that they can reduce the overall value of the outstanding
administrative claims quickly and increase the likelihood that general unsecured creditors will
receive some distribution. Without these Settlements, there is a substantial likelihood that no
distributions will be made to general unsecured creditors. In summary, the Settlement
Agreements and Mutual Releases are in the best interest of the Debtors’ estates, unsecured
creditors and other constituents.