EXCERPTS: "DermaStar and Ladonnikov are Prepared to Negotiate and Fund a Plan of Reorganization with the Debtor. In contrast to the Sale Motion, which strips the estate of any upside of the successful commercialization of its product and yet subjects the estate to considerable risk, DermaStar and Ladonnikov (collectively, the “Plan Sponsors”) are prepared to negotiate and, if an agreement can be reached, fund a plan of reorganization which will allow the Debtor’s creditors and shareholders to realize immediate and future dividends. In short, the Plan Sponsors are prepared to provide immediate funds to pay administrative expenses and a portion of the Debtor’s unsecured claims on confirmation; sufficient operating capital to complete the second Phase 3 trial; an experienced board and management team to oversee the final Phase 3 trial and, if approved, bring the product to market; and a commitment to bring the product to market. The Plan Sponsors, which include the Debtor’s largest unsecured creditor, believe that a plan of reorganization will yield a greater recovery for the Debtor’s creditors and shareholders without the additional risk of significant losses from Cardium’s business lines with significant historical losses.
CONCLUSION For the foregoing reasons, Ladonnikov and DermaStar respectfully request that the Court either (1) deny the Sale Motion; or (2) deny the break-up fee and continue the hearing on the Sale Motion for 20 days to allow the Debtor and the Plan Sponsors to engage in negotiations to determine if a confirmable plan of reorganization can be proposed. DATE: JULY 11, 2011 FOLEY & LARDNER LLP VICTOR A. VILAPLANA MATTHEW J. RIOPELLE BY: /S/ MATTHEW J. RIOPELLE MATTHEW J. RIOPELLE ATTORNEYS FOR ALEXEJ LADONNIKOV AND DERMASTAR INTERNATIONAL, LLC"
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