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linda1

12/14/11 5:14 PM

#5086 RE: mrholty #5085


I missed noticing the $ 250 M for Class 16 - however, I did notice the following footnote on PG 45 of the DS -



" The Debtors’ Updated Liquidation Analysis assumes no Litigation Proceeds and an ultimate aggregate total of

$375 million for Allowed General Unsecured Claims upon final determination of all Disputed Claims. To the extent

of material Litigation Proceeds or reduction in the ultimate aggregate amount of Allowed General Unsecured

Claims, recoveries for holders of Allowed PIERS Claims could be materially higher than the given estimate.

Conversely, to the extent that confirmation of the Seventh Amended Plan is further delayed, the Class of PIERS

Claims will be the first Class to suffer from a deterioration or elimination in recoveries as a result of the continued

accrual of interest and fees. "



http://www.kccllc.net/documents/0812229/0812229111212000000000005.pdf