No disrespect here, but there seems just a little more going on behind the scenes; true “A reorganization would require a plan to reorganize...and so far we have had no such plan put forth by anyone”.
However we do have the Mayer Brown “bill” filing #1652. Just for fun bring this document up and do a “keyword search”. There does appear to be a lot of hours billed regarding the Plan of Reorganization. (POR)
I searched POR, reorganization and the word strategy in the document.
The following are a few of my favorites;
01/03/13 Reimer, Craig E. 0.60
Email (0.20) and calls (0.40) with tax counsel (S. O'Brien and J. Hunt) regarding preservation of NOL, court procedures for obtaining commitments by substantial equity holders and plan of reorganization options.
02/22/13 Hyman, Frederick D. 4.80
Review draft term sheets for precedent (0.70). Continue working on preliminary draft of term sheet for plan, including, terms of preferred shares and warrants
(4.10).
And a few more billings addressing reorganization; POR
12/12/12 Reimer, Craig E. 1.10
Prepare for and participate in conference call with Opportune and ATP to go over issues regarding analysis of M&M liens and process for addressing same in connection with facilitating sale and/or plan of reorganization in chapter 11 case (0.80), follow-up discussions with C. Walsh regarding excel spreadsheets to prepare and legal research to perform relating to such lien analysis (0.30).
12/20/12 Lotito, Michael F. 1.70
Participated in conference call with ATP and advisors regarding plan formulation (0.60); conference with H. Beltzer, F. Hyman, and C. Walsh regarding same (0.30); researched precedent for disclosure statement, plan of reorganization,and confirmation order (0.80).
01/04/13 Toland, Rue K. 2.10
Research and analyze rights offerings in conjunction with plans of
reorganization.
01/30/13 Lotito, Michael F. 0.20
Attention to draft plan of reorganization term sheet with F. Hyman.
02/04/13 Beltzer, Howard S. 0.10
Conference with R. Hyman regarding POR issues.
02/06/13 Gray, Robert F. 2.10
Telephone conference with MB lawyers to develop POR strategy for case (1.40). Conference with Charles regarding alternative structures and interests of constituents (DIP, Seconds and UCC) in light of most recent pronouncements by Judge Isger regarding UCC (0.70).
02/08/13 Kelley, Charles S. 2.10
Meeting with Al and Keith and Bob to discuss plan concepts and strategy towards plan structure.
02/13/13 Kelley, Charles S. 1.00
Internal call with B. Trust to discuss POR planning and strategizing.
02/14/13 Beltzer, Howard S. 0.10
Read correspondence from T. Janne regarding POR concepts.
02/22/13 Beltzer, Howard S. 0.10
Correspondence with R. Hyman, T. Janne, C. Kelley regarding POR outline.
02/25/13 Beltzer, Howard S. 2.10
Read draft plan outline (0.70). Related conferences with R. Hyman (0.30). Telephone conference with R. Silverman (with R. Hyman) (0.20). Conference call with MB/Jefferies/Opportune team (0.90).
02/25/13 Gray, Robert F. 1.70
Review Preliminary Term Sheet for Chapter 11 Plan (1.00). Attend telephone conferences with Jefferies and MB re same (0.70).
02/25/13 Hyman, Frederick D. 3.30
Edits to plan term sheet (1.00). Call with plan sub group regarding plan structure (0.90). Edits to term sheet (1.00). Follow-up with R. Silverman regarding plan alternatives (0.20). Call with Bingham regarding same (0.20).
02/25/13 Lotito, Michael F. 1.20
Prepared for and participated in conference call with advisors to debt regarding plan formulation.
02/26/13 Beltzer, Howard S. 0.50
Conference with R. Hyman (0.20). Telephone conference with C. Kelley regarding issues regarding POR outline (0.10). Attention thereto (0.20).
02/26/13 Hyman, Frederick D. 2.00
Work on plan term sheet.
02/26/13 Lotito, Michael F. 0.50
Conference with F. Hyman on plan formulation.
02/27/13 Beltzer, Howard S. 0.10
Conference with M. Lotito regarding credit bid issues.
02/27/13 Hyman, Frederick D. 1.90
Work on edits/updates to plan term sheet (1.50). Call with Jefferies regarding credit bidding issues (0.40).
02/28/13 Kelley, Charles S. 2.30
Meeting with J. Latimer, J. Homier and A. Reese to discuss strategy on plan structure and related items.
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