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Full title: Chapter 11 Plan of Reorganization [Submission of Confirmed Second Amended Joint Chapter 11 Plan of Liquidation Proposed by Debtors and Official Committee of Unsecured Creditors, as Modified] Filed by Debtor Freedom Communications, Inc.. (Friedman, Alan) (Entered: 07/12/2021)

Document posted on Jul 11, 2021 in the bankruptcy, 40 pages and 0 tables.

Bankrupt11 Summary (Automatically Generated)

(30calendar days following the date on which such Priority Non-Tax Claim becomes an Allowed Priorit28 Non-Tax Claim, (a) a Cash payment from the Liquidating Debtors equal to the Allowed amount 1 such Claim, or (b) such other treatment as otherwise agreed by the Holder of such Claim and thDebtors or the Liquidating Debtors.Miscellaneous Secured Claim shall be reinstated and Unimpaired in accordance with section 1124 othe Bankruptcy Code, or (ii) each Holder of an Allowed Miscellaneous Secured Claim shall receiv13 in full satisfaction, settlement, and release of, and in exchange for, such Miscellaneous Secured Clai(x) payment in full in Cash of the unpaid portion of such Allowed Miscellaneous Secured Claim, (y14 the collateral securing such Allowed Miscellaneous Secured Claim, or (z) such other treatment as mabe agreed to by the Holder of such Claim and the Debtors or the Liquidating Debtors.The Plan Administrator shall serve in such capacity through the earlier of the dat17 that all of the Debtors are dissolved in accordance with this Plan and the date such Plan Administratoresigns, is terminated or otherwise unable to serve; provided, however, that any successor Pla18 Administrator appointed pursuant to the Plan shall serve in such capacity after the effective date such person’s appointment as Plan Administrator.Any objection to a Claim shall be filed with the Bankruptcy Court and served on the Perso4 holding such Claim within one hundred eighty (180) calendar days after the Effective Date (as mabe extended pursuant to this section, the “Objection Deadline”), provided that the Liquidating Debtor5 may seek one or more extensions thereof subject to Bankruptcy Court approval and with notice onlto parties that have requested such notice pursuant to Bankruptcy Rule 2002.Effective Date; 23 (c) resolve any matters related to the rejection of any executory contract or unexpired lease twhich any of the Debtors is a party or with respect to which any of the Debtors may be liable, and t24 hear, determine and, if necessary, liquidate any Claims arising therefrom; 25 (d)ensure that distributions to Holders of Allowed Claims are made pursuant to the provisionof the Plan, and to effectuate performance of the provisions of the Plan; 26 (e) decide or resolve any motions, adversary proceedings, contested or litigated matters an27 any other matters and grant or deny any applications involving any of the Debtors that may be pendinbefore the Effective Date or that may be commenced thereafter as provided in the Plan; 28 1 (f) enter such orders as may be necessary or appropriate to implement or consummate thprovisions of the Plan and all contracts, instruments, releases, indentures and other agreements 2 documents created in connection with the Plan, the Disclosure Statement or the Confirmation Ordeexcept as otherwise provided in the Confirmation Order or in the Plan, including, without limitatio3 any stay orders as may be appropriate in the event t

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1 Alan J. Friedman - Bar No. 132580 Robert J. Feinstein (Pro Hac Vice) Rika M. Kido - Bar No. 273780 Jeffrey W. Dulberg (Bar No. 181200) 2 SHULMAN BASTIAN FRIEDMAN & BUI LLP PACHULSKI STANG ZIEHL & JONES LL100 Spectrum Center Drive, Suite 600 10100 Santa Monica Blvd., 13th Floor 3 Irvine, California 92618 Los Angeles, CA 90067 Telephone: (949) 340-3400 Telephone: (310) 277-6910 4 Facsimile: (949) 340-3000 Facsimile: (310) 201-0760 Email: AFriedman@shulmanbastian.com Email: rfeinstein@pszjlaw.com 5 RKido@shulmanbastian.com jdulberg@pszjlaw.com 6 Counsel for Debtors and Co-Plan Proponents Counsel for the Official Committee of Unsecured Creditors 7 Co-Plan Proponents 8 UNITED STATES BANKRUPTCY COURT 9 CENTRAL DISTRICT OF CALIFORNIA, SANTA ANA DIVISION 10 11 In re Case No. 8:15-bk-15311-MW 12 FREEDOM COMMUNICATIONS, INC., a Chapter 11 Delaware corporation et al., 13 (Jointly Administered with Case Nos. Debtors and Debtors-in- 8:15-bk-15312-MW; 8:15-bk-15313-MW; 14 Possession. 8:15-bk-15315-MW; 8:15-bk-15316-MW; 8:1 Affects: bk-15317-MW; 8:15-bk-15318-MW; 8:15-bk- 15 15319-MW; 8:15-bk-15320-MW; 8:15-bk-  All Debtors 15321-MW; 8:15-bk-15322-MW; 8:15-bk- 16 15323-MW; 8:15-bk-15324-MW; 8:15-bk- Freedom Communications, Inc., a 15325-MW; 8:15-bk-15326-MW; 8:15-bk-17 Delaware corporation, ONLY 15327-MW; 8:15-bk-15328-MW; 8:15-bk- 15329-MW; 8:15-bk-15330-MW; 8:15-bk- 18 Freedom Communications Holdings, Inc., 15332-MW; 8:15-bk-15337-MW; 8:15-bk-a Delaware corporation, ONLY 15339-MW; 8:15-bk-15340-MW; 19 8:15-bk-15342-MW; 8:15-bk-15343-MW) Freedom Services, Inc., a Delaware 20 corporation, ONLY SUBMISSION OF CONFIRMED SECOND AMENDED JOINT CHAPTER 11 PLAN 21 2100 Freedom, Inc., a Delaware OF LIQUIDATION PROPOSED BY corporation, ONLY DEBTORS AND OFFICIAL COMMITTE 22 OF UNSECURED CREDITORS, AS OCR Community Publications, Inc., a MODIFIED 23 California corporation, ONLY Confirmation Hearing: 24 Daily Press, LLC, a California limited Date: July 7, 2021 liability company, ONLY Time: 2:00 p.m. 25 Place: Courtroom 6C Freedom California Mary Publishing, Inc., United States Bankruptcy Court 26 a California corporation, ONLY Ronald Reagan Federal Building 411 W. Fourth Street 27 Freedom California Ville Publishing Santa Ana, CA 92701 Company LP, a California limited partnership,

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1 Freedom Colorado Information, Inc., a 2 Delaware corporation, ONLY 3 Freedom Interactive Newspapers, Inc., a California corporation, ONLY 4 Freedom Interactive Newspapers of Texas, 5 Inc., a Delaware corporation, ONLY 6 Freedom Newspaper Acquisitions, Inc., a Delaware corporation, ONLY 7 Freedom Newspapers, a Texas general 8 partnership, ONLY 9 Freedom Newspapers, Inc., a Delaware corporation, ONLY 10 Freedom Newspapers of Southwestern 11 Arizona, Inc., a California corporation, ONLY 12 OCR Information Marketing, Inc., a California corporation, ONLY 13 Odessa American, a Texas general 14 partnership, ONLY 15 Orange County Register Communications, Inc., a California corporation, ONLY 16 Victor Valley Publishing Company, a 17 California corporation, ONLY 18 Victorville Publishing Company, a California limited partnership, ONLY 19 Freedom SPV II, LLC, a Delaware limited 20 liability company, ONLY 21 Freedom SPV VI, LLC, a Delaware limited liability company, ONLY 22 Freedom SPV I, LLC, a Delaware limited 23 liability company, ONLY 24 Freedom SPV IV, LLC, a Delaware limited liability company, ONLY 25 Freedom SPV V, LLC, a Delaware limited 26 liability company, ONLY 27

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1 Attached is a copy of the Second Amended Joint Chapter 11 Plan of Liquidation Propose2 by Debtors and Official Committee of Unsecured Creditors, as Modified (“Plan”) which wa3 confirmed by the Court and approved at the confirmation hearing held on July 7, 2021. No change4 to the Plan were made, the Plan being the same as that filed with the Court on May 6, 2021 [Dock5 No. 1760]. 6 7 Respectfully submitted, 8 SHULMAN BASTIAN FRIEDMAN & BUI LLP 9 10 DATED: July 12, 2021 By: /s/ Alan J. Friedman 11 Alan J. Friedman Rika M. Kido 12 Attorneys for Debtors and Co-Plan Proponents 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27

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1 Alan J. Friedman (Bar No. 132580) Robert J. Feinstein (Pro Hac Vice) SHULMAN BASTIAN FRIEDMAN & BUI Jeffrey W. Dulberg (Bar No. 181200) 2 LLP PACHULSKI STANG ZIEHL & JONES LLP 100 Spectrum Center Drive, Suite 600 10100 Santa Monica Blvd., 13th Floor 3 Irvine, California 92618 Los Angeles, CA 90067 Telephone: (949) 340-3400 Telephone: (310) 277-6910 4 Facsimile: (949) 340-3000 Facsimile: (310) 201-0760 Email: afriedman@shulmanbastian.com Email: rfeinstein@pszjlaw.com 5 jdulberg@pszjlaw.com Counsel for the Debtors 6 Co-Plan Proponents Counsel for the Official Committee of Unsecured Creditors 7 Co-Plan Proponents 8 UNITED STATES BANKRUPTCY COURT 9 CENTRAL DISTRICT OF CALIFORNIA 10 SANTA ANA DIVISION 11 In re: Case No.: 8:15-bk-15311-MW 12 FREEDOM COMMUNICATIONS, INC., a Chapter 11 Delaware corporation, et al.,1 13 (Jointly Administered with Case Nos. Debtors and 8:15-bk-15312-MW; 8:15-bk-15313-MW; 14 Debtors-in-Possession. 8:15-bk-15315-MW; 8:15-bk-15316-MW; _______________________________________ 8:15-bk-15317-MW; 8:15-bk-15318-MW; 15 8:15-bk-15319-MW; 8:15-bk-15320-MW; Affects: 8:15-bk-15321-MW; 8:15-bk-15322-MW; 16 8:15-bk-15323-MW; 8:15-bk-15324-MW; All Debtors 8:15-bk-15325-MW; 8:15-bk-15326-MW; 17 8:15-bk-15327-MW; 8:15-bk-15328-MW; Freedom Communications, Inc., a Delaware 8:15-bk-15329-MW; 8:15-bk-15330-MW; 18 corporation, ONLY 8:15-bk-15332-MW; 8-15-bk-15337-MW; 8:15-bk-15339-MW; 8-15-bk-15340-MW; 19 Freedom Communications Holdings, Inc., a 8:15-bk-15342-MW; 8:15-bk-15343-MW) Delaware corporation, ONLY 20 21 Freedom Services, Inc., a Delaware corporation, ONLY 22 23 1 The last four digits of the Debtors’ federal tax identification numbers are as follows: Freedom Communications, In24 (0750); Freedom Communications Holdings, Inc. (2814); Freedom Services, Inc. (3125); 2100 Freedom, Inc. (7300); OCommunity Publications, Inc. (9752); Daily Press, LLC (3610); Freedom California Mary Publishing, Inc. (41225 Freedom California Ville Publishing Company LP (7735); Freedom Colorado Information, Inc. (7806); FreedoInteractive Newspapers, Inc. (9343); Freedom Interactive Newspapers of Texas, Inc. (8187); Freedom Newspap26 Acquisitions, Inc. (4322); Freedom Newspapers (7766); Freedom Newspapers, Inc. (3240); Freedom Newspapers Southwestern Arizona, Inc. (5797); OCR Information Marketing, Inc. (7983); Odessa American (7714); Orange Coun27 Register Communications, Inc. (7980); Victor Valley Publishing Company (6082); Victorville Publishing Compa(7617); Freedom SPV II, LLC (8253); Freedom SPV VI, LLC (8434); Freedom SPV I, LLC (3293); Freedom SPV ILLC (8500); and Freedom SPV V, LLC (9036). The Debtors’ mailing address is 625 N. Grand Avenue, Santa An28

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1 2100 Freedom, Inc., a Delaware SECOND AMENDED JOINT CHAPTER 1corporation, ONLY PLAN OF LIQUIDATION PROPOSED BY 2 DEBTORS AND OFFICIAL COMMITTEE OCR Community Publications, Inc., a OF UNSECURED CREDITORS, AS 3 California corporation, ONLY MODIFIED 4 Daily Press, LLC, a California limited Disclosure Statement Approval Hearing: liability company, ONLY Date: April 28, 2021 5 Time: 2:00 p.m. Freedom California Mary Publishing, Inc., Place: Courtroom 6C 6 a California corporation, ONLY 411 West Fourth Street Santa Ana, CA 92701 7 Freedom California Ville Publishing Company LP, a California limited partnership, Judge: Honorable Mark S. Wallace 8 ONLY 9 Freedom Colorado Information, Inc., a Confirmation Hearing: Delaware corporation, ONLY Date: July 7, 2021 10 Time: 2:00 p.m. Freedom Interactive Newspapers, Inc., Place: Courtroom 6C 11 a California corporation, ONLY 411 West Fourth Street Santa Ana, CA 92701 12 Freedom Interactive Newspapers of Texas, Judge: Honorable Mark S. Wallace Inc., a Delaware corporation, ONLY 13 Freedom Newspaper Acquisitions, Inc., 14 a Delaware corporation, ONLY 15 Freedom Newspapers, a Texas general partnership, ONLY 16 Freedom Newspapers, Inc., a Delaware 17 corporation, ONLY 18 Freedom Newspapers of Southwestern Arizona, Inc., a California corporation, ONLY 19 OCR Information Marketing, Inc., a 20 California corporation, ONLY 21 Odessa American, a Texas general partnership, ONLY 22 Orange County Register Communications, Inc., a California corporation, ONLY 23 Victor Valley Publishing Company, a 24 California corporation, ONLY 25 Victorville Publishing Company, a California limited partnership, ONLY 26 Freedom SPV II, LLC, a Delaware limited 27 liability company, ONLY Freedom SPV VI, LLC, a Delaware limited 28 liability company, ONLY

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1 Freedom SPV I, LLC, a Delaware limited 2 liability company, ONLY 3 Freedom SPV IV, LLC, a Delaware limited liability company, ONLY 4 Freedom SPV V, LLC, a Delaware limited 5 liability company, ONLY 6 INTRODUCTION2 7 The Debtors and the Committee hereby propose this Plan, which provides for the distributio8 of the remaining assets of the Debtors’ estates, consisting primarily of net cash proceeds from certailitigation settlements. Reference is made to the Disclosure Statement for (i) a discussion of the Debtor9 history, businesses, assets and liabilities, (ii) a summary and analysis of this Plan, and (iii) certairelated matters, including risk factors relating to the consummation of this Plan and Distributions t10 be made under this Plan. The Debtors and the Committee are the proponents of the Plan within thmeaning of section 1129 of the Bankruptcy Code. 11 This Plan provides for the liquidation, collection, disposition and distribution of the remainin12 assets of the Debtors’ Estates and winding-up the Debtors’ affairs and the Chapter 11 CaseSubstantially all of the Debtors’ commercial assets were sold to a third party buyer and remainin13 material causes of action of the Debtors were addressed and resolved under certain settlementincluding with the Pension Benefit Guaranty Corporation. The Plan proposes to fairly and efficientl14 allocate the Debtors’ remaining Distributable Assets in a manner that is supported by the principconstituencies in the Chapter 11 Cases and will allow such cases to be promptly resolved. 15 This Plan will be implemented through the substantive consolidation of the Debtors’ Estate fo16 the purposes of voting and Distributions under the Plan, the re-vesting of the Estates’ assets iLiquidating Debtor Freedom Communications, Inc., and the utilization of the current CRO as the Pla17 Administrator to liquidate or otherwise dispose of the Estates’ remaining assets, if and to the extesuch assets were not previously monetized or otherwise transferred by the Debtors prior to th18 Effective Date. All Intercompany Claims will be waived and eliminated. The Plan Administrator wiact for the Liquidating Debtors in the same fiduciary capacity as applicable to a board of directors o19 a Delaware corporation implementing such liquidation and wind-down as contemplated under thiPlan, subject to the provisions hereof, and shall, among other powers, wind up the affairs of th20 Liquidating Debtors; use, manage, sell, abandon and/or otherwise dispose of the remaining propertof the Estates; prosecute objections to Claims and any litigation on behalf of the Liquidating Debtor21 cause distributions to be made to Creditors pursuant to this Plan; and take such other actions requireunder or consistent with this Plan. 22 Under the Plan, all assets will be distributed in accordance with the priorities established in th23 Bankruptcy Code, including payment in full on the Effective Date of Allowed AdministrativExpenses, unless otherwise agreed with the Holders of such Claims. 24 The Holders of Allowed Miscellaneous Secured Claims will either: (a) be paid in cash up t25 the value of their collateral, or (b) have their obligations assumed or otherwise addressed as providefor herein, including pursuant to agreements with such Holders. As discussed in the Disclosur26 Statement, the Secured Claims of the Debtors’ prepetition secured lenders, the debtor-in-possessiofinancing lenders, and the PBGC were paid in full or otherwise addressed and resolved prior to th27 28 2 Capitalized terms used in this Introduction have the meanings ascribed to those terms in Article I below.

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1 filing of this Plan. 2 Holders of Allowed General Unsecured Claims in Class 3 will receive any remaining NDistributable Estate Assets after the payment of (or reserves for) Allowed Administrative Expense3 Allowed Priority Tax Claims, Allowed Priority Non-Tax Claims, Allowed Miscellaneous SecureClaims, and Plan Expenses; provided that in the event that the aggregate Cash recovery for Holders 4 Allowed General Unsecured Claims (other than the PBGC) exceeds $1,000,000, then any excess Casproceeds will be shared ratably by the Holders of Allowed General Unsecured Claims and the Hold5 of the PBGC Unsecured Claims in Class 4. The PBGC (or other Holder of the PBGC UnsecureClaims) will receive the treatment provided for the PBGC Unsecured Claims set forth in the PBG6 Settlement, including, as noted, the PBGC sharing ratably with Holders of Allowed Class 3 GenerUnsecured Claims any excess Cash proceeds over $1,000,000 in the aggregate. 7 Lastly, all Interests in the Debtors will be canceled, and any associated management rights hel8 by Holders of Interests will be void and of no force and effect as of the Effective Date. Holders Interests will not receive any Distribution or other property pursuant to the Plan. 9 The Disclosure Statement distributed with this Plan contains a discussion of, among othe10 things, the Debtors’ history, a summary of the Debtors’ assets and liabilities, a summary of whHolders of Claims and Interests will receive under this Plan, a discussion of certain alternatives to thi11 Plan, and a summary of the procedures and voting requirements necessary for Confirmation of thiPlan. The Disclosure Statement is intended to provide Holders of Claims with information sufficie12 to enable such Holders to vote on this Plan. 13 No solicitation materials, other than the Disclosure Statement and related materials transmittetherewith, have been approved for use in soliciting acceptances and rejections of this Plan. Nothin14 in the Plan should be construed as constituting a solicitation of acceptances of the Plan unless and untthe Disclosure Statement has been approved and distributed to all Holders of Claims to the exte15 required by section 1125 of the Bankruptcy Code. 16 ALL HOLDERS OF CLAIMS ENTITLED TO VOTE ON THE PLAN ARE ENCOURAGETO READ CAREFULLY THE DISCLOSURE STATEMENT AND THE PLAN, EACH IN IT17 ENTIRETY, BEFORE VOTING TO ACCEPT OR REJECT THE PLAN. 18 ARTICLE I 19 DEFINED TERMS AND RULES OF INTERPRETATION 20 For purposes of “this Plan” or “the Plan” as used herein: 21 (a) whenever from the context it is appropriate, each term, whether stated in the singular othe plural, shall include both the singular and the plural, and pronouns stated in the masculine, feminin22 or neuter gender shall include the masculine, feminine and neuter gender; 23 (b) any reference in the Plan to a contract, instrument, release, indenture, or other agreeme24 or document being in a particular form or on particular terms and conditions means that such documeshall be substantially in such form or substantially on such terms and conditions; 25 (c) any reference in the Plan to an existing document or exhibit Filed, or to be Filed, sha26 mean such document or exhibit, as it may have been or may be amended, modified or supplemented27 (d) unless otherwise specified, all references in the Plan to sections and exhibits are referenceto sections and exhibits of or to the Plan; 28

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1 (e) the words “herein,” “hereof,” “hereto,” “hereunder,” “herewith,” and other words osimilar import refer to the Plan in its entirety rather than to a particular portion of the Plan; 2 (f) the rules of construction set forth in section 102 of the Bankruptcy Code shall apply;3 (g) any term used in capitalized form in the Plan that is not defined in the Plan, but that is use4 in the Bankruptcy Code or the Bankruptcy Rules, shall have the meaning set forth in the Bankruptc5 Code or the Bankruptcy Rules, as the case may be; and 6 (h) the definition given to any term or provision in the Plan supersedes and controls andifferent meaning that may be given to that term or provision in the Disclosure Statement, on an7 Ballot, or in any other document other than the Confirmation Order. 8 In computing any period of time prescribed or allowed by the Plan, the provisions Bankruptcy Rule 9006(a) shall apply. 9 The following capitalized terms used in the Plan shall have following meanings: 10 11 1.1 Administrative Expense: An unpaid administrative expense of the kind described in section365, 503(b) and 507(a)(2) of the Bankruptcy Code against any of the Debtors, including, witholimitation, (a) the actual, necessary costs and expenses of preserving the Estates of the Debtors, (12 compensation and reimbursement of expenses of professionals and reimbursement of expenses oCommittee members, in each case, to the extent allowable under sections 327, 328, 330(a), 331, 503(13 and/or 1103 of the Bankruptcy Code and Allowed or otherwise payable pursuant to orders of thBankruptcy Court, and (c) all fees and charges assessed against the Estates under 28 U.S.C. § 19314 including U.S. Trustee Fees. 15 1.2 Allowed, Allowed Claim, or Allowed [ ] Claim: With respect to any Claim or Interesexcept as otherwise provided herein: (a) a Claim that has been scheduled by any of the Debtors in thei16 Schedules as other than disputed, contingent or unliquidated which has not been superseded by a fileproof of claim and which scheduled Claim has not been amended; (b) a Claim that has been allowe17 by a Final Order; (c) a Claim that is allowed by the Liquidating Debtors on or after the Effective Datand, to the extent necessary, approved by the Bankruptcy Court; (d) a Claim that has been timely file18 by the Bar Date for which no objection has been filed by the Objection Deadline; or (e) a Claim this allowed pursuant to the terms of this Plan. For the avoidance of doubt: (i) Claims allowed solel19 for the purpose of voting to accept or reject the Plan pursuant to an order of the Bankruptcy Court shanot be considered “Allowed Claims” hereunder solely by virtue of being allowed for voting purpose20 and (ii) except for any Claim that is expressly Allowed herein, any Claim that has been or is hereaftelisted in the Schedules as contingent, unliquidated or disputed and for which no Proof of Claim ha21 been Filed shall not be considered Allowed under this Plan. 22 1.3 Avoidance Claims: Any Rights of Action arising under chapter 5 of the Bankruptcy Code oapplicable federal or state law and the proceeds thereof. As discussed in the Disclosure Statement, th23 Debtors and Liquidating Debtors prosecuted or otherwise pursued numerous Avoidance Claims prito the filing of the Plan, and do not anticipate prosecuting any Avoidance Claims after the Effectiv24 Date. 25 1.4 Ballot: The form approved by the Bankruptcy Court and distributed to each Holder of aImpaired Claim entitled to vote on the Plan, on which is to be indicated, among other thing26 acceptance or rejection of the Plan. 27 1.5 Bankruptcy Code: Title 11 of the United States Code, 11 U.S.C. §§ 101–1532 (as may bamended). 28

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1 1.6 Bankruptcy Court: The United States Bankruptcy Court for the Central District of Californior in the event such court ceases to exercise jurisdiction over any Chapter 11 Case, such court o2 adjunct thereof that exercises jurisdiction over such Chapter 11 Case in lieu of the United StateBankruptcy Court for the Central District of California. 3 1.7 Bankruptcy Rules: The Federal Rules of Bankruptcy Procedure promulgated pursuant t4 28 U.S.C. § 2075, as now in effect or hereinafter amended, together with the Local Rules of thBankruptcy Court. 5 1.8 Bar Date: The applicable deadlines in the Chapter 11 Cases for filing any and all Claim6 (including Administrative Expenses). 7 1.9 Bar Date Order: The order or orders of the Bankruptcy Court setting the Bar Date, includinthe Order Granting Motion for Order Establishing a Bar Date for Filing Proofs of Claim an8 Approving Form and Manner of Notice of Bar Date [Docket No. 355]. 9 1.10 Business Day: Any day, other than a Saturday, a Sunday or a “legal holiday,” as defined iBankruptcy Rule 9006(a). 10 1.11 Cash: Currency of the United States of America and cash equivalents, including, but n11 limited to, bank deposits, immediately available or cleared checks, drafts, wire transfers and othesimilar forms of payment. 12 1.12 Chapter 11 Cases: (a) When used with reference to a particular Debtor, the case pending fo13 that Debtor under chapter 11 of the Bankruptcy Code and (b) when used with reference to all Debtorthe procedurally consolidated chapter 11 cases pending for the Debtors in the Bankruptcy Court unde14 case number 15-bk-15311-MW. 15 1.13 Claim: Any claim against any of the Debtors or any property of the Debtors within thmeaning of section 101(5) of the Bankruptcy Code including, without limitation, claims of the kin16 specified in sections 502(g), 502(h), or 502(i) of the Bankruptcy Code. 17 1.14 Class: Each category of Claims or Interests classified in Article III of the Plan pursuant tsection 1122 of the Bankruptcy Code. 18 1.15 Class 3 Distribution Date(s): This term has the meaning set forth in Section 3.2.3 of this Pla19 1.16 Committee: The Official Committee of Unsecured Creditors appointed by the U.S. Truste20 in these Chapter 11 Cases, as it may be reconstituted from time to time. 21 1.17 Committee Retained Professionals: The Committee’s attorneys and other professional(solely in their respective capacity as professionals of the Committee). 22 1.18 Confirmation: The approval by the Bankruptcy Court of this Plan in accordance with th23 provisions of chapter 11 of the Bankruptcy Code, as effectuated by the Confirmation Order. 24 1.19 Confirmation Date: The date on which the clerk of the Bankruptcy Court enters thConfirmation Order on the docket of the Chapter 11 Cases. 25 1.20 Confirmation Hearing: The hearing(s) on Confirmation of the Plan, to be held on the dat26 or dates established by the Bankruptcy Court pursuant to section 1129 of the Bankruptcy Code, as may be adjourned or continued from time to time. 27 1.21 Confirmation Order: The order entered by the Bankruptcy Court confirming the Plan. 28

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1 1.22 Consummation: Substantial consummation of the Plan as that term is used in section 1127(bof the Bankruptcy Code. 2 1.23 Creditor: Any Person who is the Holder of a Claim. 3 1.24 Debtor Retained Professionals: The Debtors’ attorneys and other professionals (solely i4 their respective capacity as attorneys or other professionals of the Debtors). 5 1.25 Debtors: The debtors and debtors in possession in the Chapter 11 Cases. 6 1.26 Disallowed or Disallowed Claim: With respect to any Claim, except as otherwise provideherein, a Claim or any portion thereof that (a) has been disallowed by agreement with the credito7 (b)has been disallowed by Final Order, (c) is listed in the Schedules in an unknown amount, as zeras contingent, disputed, or unliquidated, or is not listed in the Schedules, and as to which no proof o8 Claim or Administrative Expense has been Filed, or (iv) has been withdrawn by the applicable credito9 1.27 Disclosure Statement: The Second Amended Disclosure Statement in Respect of SeconAmended Joint Chapter 11 Plan of Liquidation Proposed By Debtors and Official Committee 10 Unsecured Creditors, as it may be amended, modified or supplemented from time to time, submittepursuant to section 1125 of the Bankruptcy Code in connection with the solicitation of acceptances 11 the Plan. 12 1.28 Disputed: With respect to any Claim or Interest, any Claim or Interest that is: (a) disputeunder the Plan, or subject to a timely objection and/or request for estimation in accordance with sectio13 502(c) of the Bankruptcy Code and Bankruptcy Rule 3018, which objection and/or request foestimation has not been withdrawn or determined by a Final Order; (b) a Claim, on account of whic14 a proof of Claim was filed or which has been otherwise asserted and in respect of which Claim thObjection Deadline has not expired, (i) for which a corresponding Claim has not been listed in th15 Debtors’ Schedules or for which the corresponding Claim is listed in the Debtors’ Schedules with lower amount, with a differing classification, or as disputed, contingent, or unliquidated, (ii) whic16 has not been allowed either by a Final Order, by the Plan, or under a stipulation or settlement with thDebtors or the Liquidating Debtors, and (iii) which Claim the Plan Administrator has not determine17 will not be subject to an objection or request for estimation; (c) contingent or unliquidated; (improperly asserted, by the untimely or otherwise improper filing of proof of such Claim as require18 by order of the Bankruptcy Court; or (e) any other Claim that is not Allowed. A Claim that is Disputeas to its amount shall not be Allowed in any amount for purposes of distribution until it is no longe19 Disputed. 20 1.29 Distributable Assets: Except as otherwise noted below, any and all real or personal propertof any of the Debtors of any nature, including, without limitation, any Claims, Retained Rights o21 Action, books and records, any other general intangibles of any of the Debtors, and any and aproceeds of the foregoing, as the case may be, of any nature whatsoever (whether liquidated 22 unliquidated, matured or unmatured, or fixed or contingent), including, without limitation, property the applicable Estate within the scope of section 541 of the Bankruptcy Code. Notwithstanding th23 foregoing, the term “Distributable Assets” does not include any property that has been abandoned bany Estate pursuant to a Final Order of the Bankruptcy Court. 24 1.30 Distributable Estate Assets: Collectively, (i) the Cash on hand of the Debtors from and afte25 the Effective Date (which was approximately $2,215,140.08 in Cash as of June 2, 2020); (ii) RetaineRights of Action; and (iii) any other remaining property or assets of the Debtors immediately prior t26 the Effective Date. 27 1.31 Distribution: The transfer of Cash or other property by the Plan Administrator to the Holderof Allowed Claims. 28

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1 1.32 Effective Date: The first Business Day immediately following the first day upon which all the conditions to the occurrence of the Effective Date have been satisfied or waived in accordanc2 with the Plan. 3 1.33 Equity Security: Any equity security as defined in section 101(16) of the Bankruptcy Codin a Debtor. 4 1.34 Estates: The estates created pursuant to section 541(a) of the Bankruptcy Code upon th5 commencement of the Chapter 11 Cases. 6 1.35 Excess Net Distributable Assets: This term has the meaning set forth in Section 3.2.3 of thiPlan. 7 1.36 Exculpated Parties: Each in their capacities as such, (a) the Debtors, (b) the present an8 former officers, directors, managers, and employees of the Debtors who served in such capacities any point from and after the Petition Date, (c) the Debtor Retained Professionals, (d) the Committe9 and its present and former members (solely in their respective capacity as members of the Committee(e)the Committee Retained Professionals, and (f) the respective successors or assigns of the foregoin10 parties. 11 1.37 FCI: Debtor Freedom Communications, Inc., either in its capacity as debtor and debtor ipossession under chapter 11 of the Bankruptcy Code in the Chapter 11 Cases or otherwise from an12 after the Effective Date. 13 1.38 Fee Applications: Applications of Professional Persons for allowance of compensation anreimbursement of expenses incurred in the Chapter 11 Cases 14 1.39 File or Filed: Filed of record and entered on the docket in the Chapter 11 Cases. 15 1.40 Final Decree: The order entered pursuant to section 350 of the Bankruptcy Code an16 Bankruptcy Rule 3022 closing a Chapter 11 Case. 17 1.41 Final Order: A judgment, order, ruling or other decree issued and entered by the BankruptcCourt or by any state or other federal court or other tribunal which judgment, order, ruling or othe18 decree has not been reversed, stayed, revoked, modified, supplemented or amended and as to whic(a) the time to appeal or petition for review, rehearing or certiorari has expired and as to which n19 appeal or petition for review, rehearing or certiorari is pending, or (b) any appeal or petition for revierehearing or certiorari has been finally decided and no further appeal or petition for review, rehearin20 or certiorari can be taken or granted. For the avoidance of doubt, no order shall fail to be a Final Ordsolely because of the possibility that a motion pursuant to Bankruptcy Code section 502(j), Rule 59 o21 Rule 60 of the Federal Rules of Civil Procedure, or Bankruptcy Rules 9023 or 9024 may be or habeen filed with respect to such order. 22 1.42 Final Resolution Date: The date on which all Disputed Claims of Creditors shall have bee23 resolved by Final Order or otherwise finally determined. 24 1.43 General Unsecured Claim: A Claim, other than (a) an Administrative Expense, (b) a PrioritTax Claim, (c) a Priority Non-Tax Claim, (d) an Intercompany Claim, (e) a Miscellaneous Secure25 Claim, and (f) a PBGC Unsecured Claim. 26 1.44 Governmental Unit: This term shall have the meaning set forth in section 101(27) of thBankruptcy Code 27 1.45 Holder: The beneficial owner of record of any Claim or Interest. 28

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1 1.46 Impaired: This term shall have the meaning set forth in section 1124 of the Bankruptcy Cod2 1.47 Insider: This term shall have the meaning set forth in section 101(31) of the Bankruptcy Cod3 1.48 Insured Claim: Any Claim or portion of a Claim (other than a Claim held by an employee the Debtors for workers’ compensation coverage) that is insured under the Debtors’ insurance policie4 but only to the extent of such coverage. 5 1.49 Intercompany Claim: Any Claim asserted by one of the Debtors against any of the otheDebtors. 6 1.50 Interest: (a) Any Equity Security, including all membership interests, shares or simil7 securities, whether or not transferable or denominated “stock” and whether issued, unissueauthorized or outstanding; (b) any warrant, option, or contractual right to purchase, sell, subscribe 8 acquire such Equity Securities at any time and all rights arising with respect thereto; and (c) any similinterest in any of the Debtors. 9 1.51 IRS: The Internal Revenue Service. 10 1.52 Lien: Any charge against or interest in property to secure payment or performance of a Clai11 debt, or obligation. 12 1.53 Liquidating Debtors: The Debtors on and after the Effective Date. 13 1.54 Miscellaneous Secured Claim: Any Secured Claim that has not been fully paid or otherwissatisfied or resolved pursuant to order(s) of the Bankruptcy Court prior to the entry of an ord14 approving the Disclosure Statement pursuant to section 1125 of the Bankruptcy Code. For thavoidance of doubt, this term does not include any Secured Claims of the PBGC, which claims sha15 be entitled to the treatment set forth in the PBGC Settlement and PBGC Settlement Order. 16 1.55 Net Distributable Estate Assets: The Distributable Estate Assets from and after the EffectivDate, once such assets have been reduced to Cash, net of amounts paid in respect of Allowe17 Administrative Expenses, Allowed Priority Tax Claims, Allowed Priority Non-Tax Claims, AlloweMiscellaneous Secured Claims, and Plan Expenses and/or reserves established for any of the foregoin18 and excluding those Distributable Estate Assets that are subject to any Liens until such time that sucLiens are satisfied or otherwise addressed in full. 19 1.56 Objection Deadline: The deadline to object to Claims and/or Interests specified in Sectio20 8.2 of the Plan, as may be extended pursuant thereto. 21 1.57 PBGC: Pension Benefit Guaranty Corporation or its successor or assign. 22 1.58 PBGC Settlement: That certain Settlement Agreement dated November 22, 2019, betweeand among the Committee, the PBGC, and the Debtors, as amended, modified and/or supplemente23 from time to time, and as approved by the Bankruptcy Court and subject to the PBGC SettlemeOrder. 24 1.59 PBGC Settlement Order: The order of the Bankruptcy Court entered January 13, 20225 [Docket No. 1609] approving the PBGC Settlement, subject to the terms and conditions of the PBGSettlement Order. 26 1.60 PBGC Unsecured Claim(s): The general unsecured claims of the PBGC against the Debtor27 as described in the PBGC Settlement. 28 1.61 Person: Any person or organization created or recognized by law, including any associatio

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1 company, cooperative, corporation, entity, estate, fund, individual, joint stock company, joint venturlimited liability company, partnership, trust, trustee, unincorporated organization, government or an2 political subdivision thereof, or any other entity or organization of whatever nature. 3 1.62 Petition Date: November 1, 2015 or November 2, 2015, the date, as applicable, on whiceach of the Debtors filed its petition for relief under chapter 11 of the Bankruptcy Code. 4 1.63 Plan: This Second Amended Joint Chapter 11 Plan of Liquidation Proposed by Debtors an5 Official Committee of Unsecured Creditors, as it may be amended or modified from time to time. 6 1.64 Plan Administrator: Brad Smith, or any duly selected successor. 7 1.65 Plan Expenses: The expenses incurred or payable by the Liquidating Debtors following thEffective Date (including the reasonable fees and costs of attorneys and other professionals) relatin8 to implementation of the Plan, for the purpose of (a) resolving Claims and effectuating Distributionto Creditors under the Plan, (b) otherwise implementing the Plan and closing the Chapter 11 Cases, o9 (c)undertaking any other matter relating to the Plan. 10 1.66 Plan Proponents: Together, the Debtors and the Committee. 11 1.67 Plan Supplement: The supplement to the Plan to be Filed by the Plan Proponents with thBankruptcy Court, which supplement shall contain forms of certain substantially final documents (12 any) required for the implementation of the Plan, no later than ten (10) calendar days prior to thdeadline for voting on the Plan. The Plan Proponents shall have the right to amend the document13 contained in, and exhibits to, the Plan Supplement through the Effective Date. 14 1.68 Post-Effective Date Service List: Collectively, (i) the Plan Administrator; (ii) the U. Trustee; (iii) PBGC; and (iv) any other party specifically requesting service of all documents in thes15 Bankruptcy Cases from and after the Effective Date. 16 1.69 Priority Non-Tax Claim: Any Claim, other than an Administrative Expense and a PrioritTax Claim, to the extent entitled to priority under section 507(a) of the Bankruptcy Code. 17 1.70 Priority Tax Claim: A Claim that is entitled to priority under section 507(a)(8) of th18 Bankruptcy Code. 19 1.71 Pro Rata: This term means, at any time, the proportion that the face amount of a Claim in particular Class (or particular Classes, if applicable) bears to the aggregate face amount of all Claim20 (including Disputed Claims, but excluding Disallowed Claims) in such Class(es); and “face amount,as used herein, means (a) when used in reference to a Disputed Claim, the full stated liquidated amou21 claimed by the Holder of the Claim in any proof of Claim timely filed with the Bankruptcy Court otherwise deemed timely filed by any Final Order of the Bankruptcy Court or other applicabl22 bankruptcy law; and (b) when used in reference to an Allowed Claim, the allowed amount of sucClaim. 23 1.72 Pro Rata Class 3 / Class 4 Distribution Trigger Event: This term has the meaning set fort24 in Section 3.2.3 of this Plan. 25 1.73 Professional Fee Claim: An Administrative Expense of a Professional Person fcompensation for services rendered and reimbursement of costs, expenses or other charges incurre26 on or after the Petition Date and on or before the Effective Date. 27 1.74 Professional Person: Persons retained or to be compensated by the Debtors or their Estatepursuant to sections 326, 327, 328, 330, 363, 503(b), and/or 1103 of the Bankruptcy Code. 28

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1 1.75 Record Date: The Effective Date or such other date that may be approved by the BankruptcCourt. 2 1.76 Released Debtor/Committee Parties: Collectively, (i) the Debtors, (ii) the Estates, (iii) th3 Debtors’ directors, officers, managers, and employees (as applicable) who served in such capacitieduring the Chapter 11 Cases or a portion thereof, (iv) the Debtor Retained Professionals, (v) th4 Committee and its members (solely in their respective capacity as members of the Committee), (vi) thCommittee Retained Professionals, and (viii) the respective successors or assigns of the foregoin5 parties. 6 1.77 Released Parties: Collectively, (i) the Debtors’ directors, officers, managers, and employee(as applicable) who served in such capacities during the Chapter 11 Cases or a portion thereof, (ii) th7 Debtor Retained Professionals, (iii) the Committee and its members (solely in their respective capacitas members of the Committee), (iv) the Committee Retained Professionals, and (vi) the respectiv8 successors or assigns of the foregoing parties. 9 1.78 Releasing Creditor: Each Holder of a Claim that votes to accept, or is deemed to accept, thPlan, other than any Holder of a Class 3 Claim that affirmatively elects on its Ballot to opt out of bein10 a Releasing Creditor. 11 1.79 Retained Rights of Action: All Rights of Action belonging to any of the Debtors or thEstates as of the Effective Date, including, without limitation and as applicable, Avoidance Claim12 (including those disclosed in the Schedules), but excluding those Rights of Action specifically releaseunder the Plan or the Confirmation Order. The Retained Rights of Action include, without limitatio13 (x) any and all rights of the Debtors or the Estates to pursue any Rights of Action against any thirparties, whether or not pending and whether or not disclosed or referenced in the Schedules or in th14 Disclosure Statement; and (y) potential claims for tax refunds. As discussed in the DisclosurStatement, the Debtors and Liquidating Debtors do not anticipate prosecuting or otherwise pursuin15 any Avoidance Claims after the Effective Date. 16 1.80 Rights of Action: Any and all claims, demands, rights, defenses, actions, causes of actio(including, without limitation and as applicable, Avoidance Claims), suits, contracts, agreement17 obligations, accounts, defenses, offsets, powers and privileges, to the extent not otherwise previouslwaived, released, assigned, transferred or disposed of, of any kind or character whatsoever, known o18 unknown, suspected or unsuspected, whether arising prior to, on or after the Petition Date, in contraor in tort, at law or in equity, or under any other theory of law, held by any Person against any othe19 Person, and any proceeds thereof, including but not limited to (1) rights of setoff, counterclaim recoupment, and claims on contracts or for breaches of duties imposed by law; (2) the right to obje20 to Claims or Interests; (3) claims pursuant to section 362 of the Bankruptcy Code; (4) such claims andefenses as fraud, negligence, breach of fiduciary duty, corporate waste, unlawful dividends, mistak21 duress and usury; (5) all claims or rights under Bankruptcy Code sections 502, 509, 510, 542, 54544, 545, 547, 548, 549, 550, 551, 552, 553, and 558, all fraudulent-conveyance, fraudulent-transfe22 and voidable-transactions laws, all non-bankruptcy laws vesting in creditors’ rights to avoid, rescinor recover on account of transfers or obligations, all preference laws, the Uniform Fraudulent Transfe23 Act (as it may have been codified in any particular jurisdiction), the Uniform Fraudulent ConveyancAct (as it may have been codified in any particular jurisdiction), the Uniform Voidable Transaction24 Act (as it may have been codified in any particular jurisdiction), and all similar laws and statute(6)claims for tax refunds; and (7) any other claims which may be asserted against any of the Debtors25 affiliates, insiders and/or any other third parties. 26 1.81 Schedules: The schedules of assets and liabilities and statement of financial affairs filed beach Debtor with the Bankruptcy Court pursuant to Bankruptcy Rule 1007, as they have been or ma27 be amended from time to time. 28 1.82 Secured Claim: Any Claim of any Person (a) that is secured by a Lien on property in whic

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1 any of the Debtors or their Estates has an interest, which Lien is valid, perfected and enforceable annot subject to avoidance under applicable law or by reason of a Final Order but only to the extent 2 the value, as determined by the Bankruptcy Court pursuant to section 506(a) of the Bankruptcy Codof any interest of the claimant in the property of any of the Estates securing such Claim or (b) to th3 extent that such Person has a valid and enforceable right of setoff under applicable non-bankruptclaw and section 553 of the Bankruptcy Code. 4 1.83 Tax: Any tax, charge, fee, levy, impost or other assessment by any federal, state, local o5 foreign taxing authority, including, without limitation, income, excise, property, sales, transfeemployment, payroll, franchise, profits, license, use, ad valorem, estimated, severance, stam6 occupation and withholding tax. “Tax” shall include any interest or additions attributable to, imposeon or with respect to such assessments. 7 1.84 Timely Filed: With respect to a Claim, that a proof of such Claim was filed within suc8 applicable period of time fixed by the Plan, statute, or pursuant to both Bankruptcy Rule 3003(c)(3and a Final Order (including the Bar Date Order), or has otherwise been deemed timely filed by a Fin9 Order of the Bankruptcy Court. 10 1.85 Unclaimed Property: All Cash deemed to be “Unclaimed Property” pursuant to Article Vof the Plan. 11 1.86 Unimpaired: With respect to a Class of Claims or Interests, a Class of Claims or Interests th12 is not impaired within the meaning of section 1124 of the Bankruptcy Code. 13 1.87 U.S. Trustee: The Office of the United States Trustee. 14 1.88 U.S. Trustee Fees: Fees payable to the U.S. Trustee pursuant to 28 U.S.C. § 1930. 15 ARTICLE II 16 TREATMENT OF UNCLASSIFIED CLAIMS: ADMINISTRATIVE EXPENSES AND PRIORITY TAX CLAIMS 17 2.1 Introduction. As required by the Bankruptcy Code, Administrative Expenses and Priorit18 Tax Claims are not placed into voting Classes. Instead, they are left unclassified, are not considereImpaired, do not vote on the Plan, and receive treatment specified by statute, order of the Bankruptc19 Court or agreement of the parties. All postpetition payments or credits by or on behalf of the Debtorin respect of an Administrative Expense or Priority Tax Claim shall reduce the Allowed amou20 thereof. 21 2.2 Administrative Expenses. Except as otherwise provided for herein, and subject to threquirements of the Plan, on or as soon as reasonably practicable after the later of (i) the Effectiv22 Date and (ii) thirty (30) calendar days following the date on which an Administrative Expense becomean Allowed Administrative Expense, the Holder of such Allowed Administrative Expense sha23 receive, in full satisfaction, settlement, and release of and in exchange for such AlloweAdministrative Expense, (a) Cash equal to the unpaid portion of such Allowed Administrative Expens24 or (b) such other less favorable treatment as to which such Holder and the Debtors or LiquidatinDebtors shall have agreed upon in writing; provided, however, that Allowed Administrative Expense25 with respect to liabilities incurred by a Debtor in the ordinary course of business during the Chapt11 Cases may be paid in the ordinary course of business in accordance with the terms and condition26 of any agreements related thereto. Unless otherwise agreed by the Liquidating Debtors, (a) requestfor payment of all Administrative Expenses must be Filed and served as described in Section 11.2 27 the Plan, and (b) certain different and additional requirements shall apply to the AdministrativExpenses of Professional Persons as set forth in Section 11.3 of the Plan. No interest or penalties 28 any nature shall be paid in respect of an Allowed Administrative Expense.

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1 2.3 Professional Fee Claims. Professional Fee Claims shall be paid as set forth in Section 11. of the Plan. 2 2.4 Priority Tax Claims. Pursuant to section 1123(a)(1) of the Bankruptcy Code, Priority Ta3 Claims are not classified. Thus, Holders of Priority Tax Claims are not entitled to vote to accept reject the Plan. Except to the extent that a Holder of an Allowed Priority Tax Claim agrees to a les4 favorable treatment, in exchange for full and final satisfaction, settlement, and release of each AllowePriority Tax Claim, each Holder of an Allowed Priority Tax Claim due and payable on or before th5 Effective Date shall receive, on the later of (i) the Effective Date and (ii) thirty (30) calendar dayfollowing the date on which a Priority Tax Claim becomes an Allowed Priority Tax Claim, at th6 option of the Liquidating Debtors, one of the following treatments: (1) Cash in an amount equal to thamount of such Allowed Priority Tax Claim, plus interest at the rate determined under applicable non7 bankruptcy law and to the extent provided for by section 511 of the Bankruptcy Code; or (2) sucother treatment as may be agreed upon by such Holder and the Debtors or Liquidating Debtors 8 otherwise determined upon an order of the Bankruptcy Court. Any Allowed Priority Tax Claim (portion thereof) not yet due and payable as of the Effective Date will be paid by the Liquidatin9 Debtors no later than when due and payable under applicable non-bankruptcy law without regard tthe commencement of the Chapter 11 Cases; provided that upon request of the Liquidating Debtor10 the Bankruptcy Court shall determine the amount of any Disputed Priority Tax Claim. Any Holder oa Priority Tax Claim may agree to accept different treatment as to which the Liquidating Debtors an11 such Holder have agreed upon in writing. 12 2.5 Statutory Fees. All fees payable on or before the Effective Date pursuant to section 1930 title 28 of the United States Code shall be paid by the Debtors on or before the Effective Date or a13 soon as practicable thereafter. From and after the Effective Date, the Liquidating Debtors shall pathe fees assessed against their respective Estates only until such time as the particular Chapter 11 Case14 are closed, dismissed or converted. In addition, the Liquidating Debtors shall file post-confirmatioquarterly reports in conformity with the U.S. Trustee guidelines until entry of an order closing 15 converting the Chapter 11 Cases. 16 ARTICLE III 17 CLASSIFICATION AND TREATMENT OF CLASSIFIED CLAIMS AND INTERESTS 18 3.1 Summary. The categories of Claims and Interests listed below classify Claims and Interestfor all purposes, including voting, confirmation and distribution pursuant to the Plan and pursuant t19 sections 1122 and 1123(a)(1) of the Bankruptcy Code. A Claim or Interest (or a portion thereof) iclassified in a particular Class only to the extent that the Claim or Interest (or a portion thereof20 qualifies within the description of that Class. A Claim or Interest (or a portion thereof) is alsclassified in a particular Class only to the extent that such Claim or Interest (or a portion thereof) is a21 Allowed Claim or Allowed Interest in that Class and has not been paid, released or otherwise satisfieprior to the Effective Date. Any postpetition payment by or on behalf of the Estates in respect of 22 Claim shall reduce the Allowed amount thereof. 23 3.2 Classification and Treatment of Claims and Interests. 24 3.2.1 Class 1 – Priority Non-Tax Claims. 25 (a) Classification: Class 1 consists of all Priority Non-Tax Claims. 26 (b) Treatment: At the election of the Liquidating Debtors, each Holder of a Priority NoTax Claim shall receive, in full satisfaction, settlement, release, and extinguishment of such Priorit27 Non-Tax Claim, on or as soon as practicable after the later of (i) the Effective Date, or (ii) thirty (30calendar days following the date on which such Priority Non-Tax Claim becomes an Allowed Priorit28 Non-Tax Claim, (a) a Cash payment from the Liquidating Debtors equal to the Allowed amount

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1 such Claim, or (b) such other treatment as otherwise agreed by the Holder of such Claim and thDebtors or the Liquidating Debtors. 2 (c) Impairment/Voting: Class 1 Priority Non-Tax Claims are Unimpaired by the Plan, an3 Holders of such Class 1 Priority Non-Tax Claims are therefore conclusively presumed to havaccepted the Plan pursuant to section 1126(f) of the Bankruptcy Code. Accordingly, Holders of Clas4 1 Priority Non-Tax Claims are not entitled to vote to accept or reject the Plan. 5 3.2.2 Class 2 – Miscellaneous Secured Claims. 6 (a) Classification: Class 2 consists of any Miscellaneous Secured Claims. Although aMiscellaneous Secured Claims have been placed in one Class for the purposes of nomenclature, eac7 Miscellaneous Secured Claim, to the extent secured by a Lien on any property or interest in propertof any of the Debtors different from that securing any other Miscellaneous Secured Claim, shall b8 treated as being in a separate sub-Class for purposes of voting and receiving distributions under thPlan. 9 (b) Treatment: Except to the extent that a Holder of an Allowed Miscellaneous Secure10 Claim has been paid by the Debtors, in whole or in part, prior to the Effective Date, on the later o(i)the Effective Date and (ii) thirty (30) calendar days following the date on which such Miscellaneou11 Secured Claim becomes an Allowed Miscellaneous Secured Claim, at the option of the LiquidatinDebtors, in full and final satisfaction of such Miscellaneous Secured Claim, (i) each Allowe12 Miscellaneous Secured Claim shall be reinstated and Unimpaired in accordance with section 1124 othe Bankruptcy Code, or (ii) each Holder of an Allowed Miscellaneous Secured Claim shall receiv13 in full satisfaction, settlement, and release of, and in exchange for, such Miscellaneous Secured Clai(x) payment in full in Cash of the unpaid portion of such Allowed Miscellaneous Secured Claim, (y14 the collateral securing such Allowed Miscellaneous Secured Claim, or (z) such other treatment as mabe agreed to by the Holder of such Claim and the Debtors or the Liquidating Debtors. 15 (c) Impairment/Voting: Class 2 Miscellaneous Secured Claims are Unimpaired by the Pla16 and Holders of such Class 2 Miscellaneous Secured Claims are therefore conclusively presumed thave accepted the Plan pursuant to section 1126(f) of the Bankruptcy Code. Accordingly, Holders o17 Class 2 Miscellaneous Secured Claims are not entitled to vote to accept or reject the Plan. 18 3.2.3 Class 3 – General Unsecured Claims. 19 (a) Classification: Class 3 consists of all General Unsecured Claims. 20 (b) Treatment: Except to the extent that a Holder of an Allowed Class 3 General UnsecureClaim agrees to a less favorable treatment, in exchange for full and final satisfaction, settlement an21 release of the each Allowed Class 3 General Unsecured Claim, each Holder of an Allowed Class General Unsecured Claim shall receive a Cash payment equal to its Pro Rata share of the N22 Distributable Estate Assets on one or more dates (the “Class 3 Distribution Date(s|)”) as soon areasonably practicable after (i) all General Unsecured Claims have been Allowed, Disallowed 23 otherwise resolved and (ii) the payment of (or reserves for) all Allowed Administrative ExpenseAllowed Priority Tax Claims, Allowed Priority Non-Tax Claims, Allowed Miscellaneous Secure24 Claims and Plan Expenses (unless the holder of the applicable claim agrees to other less favorabltreatment); provided, however, in the event that an aggregate of at least $1,000,000 in Cash in N25 Distributable Assets is or will be distributed, as Distributions under the Plan, to the Holders of AlloweClass 3 General Unsecured Claims on account of such Claims (the “Pro Rata Class 3 / Class 26 Distribution Trigger Event”), any and all Net Distributable Assets in excess of such $1,000,000 Casthreshold (the “Excess Net Distributable Assets”) shall be distributed by the Liquidating Debtors t27 the Holders of Allowed Class 3 Claims and the PBGC (or other Holder of the Class 4 Claims), oaccount of their Class 3 and Class 4 Claims, respectively, on a Pro Rata basis as soon as reasonabl28 practicable on the Class 3 Distribution Date(s); provided further that in the discretion of the Pla

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1 Administrator, Allowed Class 3 General Unsecured Claims may receive Distributions before threconciliation of all Disputed Class 3 General Unsecured Claims provided that (x) reserves ar2 maintained for any Class 3 General Unsecured Claim that is Disputed at the time of such Distributioand (y) the Plan Administrator shall make a corrective Distribution following the resolution of an3 Disputed Claim within thirty (30) days of such resolution. 4 (c) Impairment/Voting: Class 3 General Unsecured Claims are Impaired under the PlaTherefore, Holders of such Class 3 General Unsecured Claims are entitled to vote to accept or reje5 the Plan. 6 3.2.4 Class 4 – PBGC Unsecured Claims . 7 (a) Classification: Class 4 consists of all PBGC Unsecured Claims. 8 (b) Treatment: The Holder of the PBGC Unsecured Claims shall receive the treatmeprovided for the PBGC on account of the PBGC Unsecured Claims set forth in the PBGC Settlemen9 Specifically, pursuant to the PBGC Settlement, the PBGC has agreed to waive any right to receivDistributions under the Plan, on account of the PBGC Unsecured Claims, unless and until the Pro Rat10 Class 3 / Class 4 Distribution Trigger Event occurs or is otherwise satisfied; upon the occurrence othe Pro Rata Class 3 / Class 4 Distribution Trigger Event, the PBGC shall be entitled to share on a Pr11 Rata basis with the Holders of Allowed Class 3 Claims any Excess Net Distributable Assets. Nothinin the Plan is intended to or will modify the PBGC Settlement, and in the event of any discrepanc12 between the treatment noted above and the treatment provided for the PBGC under the PBGSettlement, the terms of the PBGC Settlement govern. 13 (c) Impairment/Voting: Class 4 PBGC Unsecured Claims are Impaired under the Pla14 Therefore, Holders of such Class 4 PBGC Unsecured Claims are entitled to vote to accept or reject thPlan. 15 3.2.5 Class 5 – Interests in the Debtors. 16 (a) Classification: Class 5 consists of all Interests. 17 (b) Treatment: Holders of Interests shall receive no distributions under the Plan, and on th18 Effective Date, all Interests shall be deemed void and of no force and effect. 19 (c) Impairment/Voting: Class 5 Interests are Impaired and Holders of such Class 5 Interestare deemed to have rejected the Plan pursuant to section 1126(g) of the Bankruptcy Code. Therefor20 Holders of Class 5 Interests are not entitled to vote to accept or reject the Plan. 21 ARTICLE IV 22 ACCEPTANCE OR REJECTION OF THE PLAN 23 4.1 Identification of Unimpaired Classes. The following Classes of Claims are Unimpaireunder the Plan: 24 (a) Class 1 – Priority Non-Tax Claims 25 (b) Class 2 – Miscellaneous Secured Claims 26 4.2 Identification of Impaired Classes. The following Classes of Claims and Interests ar27 Impaired under the Plan: 28 (a) Class 3 – General Unsecured Claims

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1 (b) Class 4 – PBGC Unsecured Claims 2 (c) Class 5 – Interests in the Debtors 3 4.3 Classes Permitted and Not Permitted to Vote. Classes 1 and 2 are Unimpaired. Holders oClaims in these Classes are conclusively presumed pursuant to section 1126(f) of the Bankruptcy Cod4 to have accepted the Plan and therefore shall not be entitled to vote to accept or reject the Plan. Classe3, 4 and 5 are Impaired. Holders of Claims in Class 3 and 4 are permitted to vote to accept or reje5 the Plan. Holders of Interests in Class 5 are deemed to reject the Plan pursuant to section 1126(g) the Bankruptcy Code. The Plan Proponents reserve all rights with respect to all Claims and Interest6 classified by the Plan. An Impaired Class of Claims that votes shall have accepted the Plan if (a) thHolders of at least two-thirds in amount of the Allowed Claims actually voting in such Class hav7 voted to accept the Plan and (b) the Holders of more than one-half in number of the Allowed Claimactually voting in such Class have voted to accept the Plan. Section 1129(a)(10) of the Bankruptc8 Code shall be satisfied for purposes of Confirmation by acceptance of the Plan by an Impaired Clasof Claims. 9 4.4 Effect of Non-Voting. If no Holder of a Claim eligible to vote in a particular Class timel10 votes to accept or reject the Plan, the Plan Proponents may seek to have the Plan deemed accepted bthe Holders of such Claims in such Class for purposes of section 1129 of the Bankruptcy Code. 11 4.5 Nonconsensual Confirmation. In the event any Class of Claims votes to reject the Plan an12 given the deemed rejection of the Plan by the Holders of Interests in Class 5, the Plan Proponentrequest that the Bankruptcy Court confirm the Plan notwithstanding such rejection pursuant to sectio13 1129(b) of the Bankruptcy Code on the basis that the Plan is fair and equitable and does ndiscriminate unfairly as to the Holders of any Class of Claims or Interests. 14 4.6 Postpetition Interest. Nothing in the Plan or the Disclosure Statement shall be deemed t15 entitle the Holder of a Claim to receive postpetition interest on account of such Claim, except to thextent that the Holder of a Claim has the benefit of a Lien on assets the value of which exceeds th16 amount of such Claim or the Plan expressly provides for postpetition interest on account of such Clai17 4.7 Elimination of Vacant Classes. Any Class of Claims or Interests that does not have a Holdeof an Allowed Claim or Allowed Interest or a Claim or Interest temporarily Allowed by the Bankruptc18 Court in an amount greater than zero as of the date of the Confirmation Hearing shall be considerevacant and deemed eliminated from the Plan for purposes of voting to accept or reject the Plan and f19 purposes of determining acceptance or rejection of the Plan by such Class pursuant to sectio1129(a)(8) of the Bankruptcy Code. 20 4.8 Special Provisions Regarding Insured Claims. 21 (a) With respect to any Insured Claim, any party with rights against or under the applicabl22 insurance policy may pursue such rights. Nothing herein shall constitute a waiver of any causes oaction the Debtors or the Liquidating Debtors may hold against any Person, including the Debtors23 insurance carriers; and nothing herein is intended to, shall, or shall be deemed to preclude any Holdeof an Allowed Insured Claim from seeking and/or obtaining a distribution or other recovery from an24 insurer of the Debtors in addition to (but not in duplication of) any Distribution such Holder mareceive under the Plan; provided, however, that the Debtors and the Liquidating Debtors do not waiv25 and expressly reserve their rights to assert that any insurance coverage is property of the Estates twhich they are entitled. 26 (b) The Plan shall not modify the scope of, or alter in any other way, the rights an27 obligations of the Debtors’ insurers under their policies, and the Debtors’ insurers shall retain any anall rights, claims and defenses to liability and/or coverage that such insurers may have, including th28 right to contest and/or litigate with any party the existence, primacy and/or scope of liability and/

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1 available coverage under any alleged applicable policy. The Plan shall not operate as a waiver of another Claims the Debtors’ insurers have asserted or may assert in any proof of claim, including, witho2 limitation, any rights or defenses arising out of, or in the nature of, setoff or recoupment, or the Debtorrights and defenses to such proofs of claim. 3 ARTICLE V 4 MEANS FOR IMPLEMENTATION OF THE PLAN 5 5.1 Settlement of Intercompany Claims. Upon the Effective Date, pursuant to section 1123(6 of the Bankruptcy Code and Bankruptcy Rule 9019, each Debtor and their successors and assignhereby waive and release each other and all of their respective successors from any and a7 Intercompany Claims and Rights of Action among and between any or all of the Debtors, which waivand release shall be effective as a bar to all actions, causes of action, suits, Claims, Liens, or demand8 of any kind with respect to any Intercompany Claim or Right of Action among or between any or aof the Debtors. 9 5.2 Partial Substantive Consolidation. 10 (a) In furtherance of the settlements contained in the Plan, the entry of the Confirmatio11 Order shall constitute approval by the Bankruptcy Court, pursuant to sections 105(a) and 1123(a)(5)(of the Bankruptcy Code, as of the Effective Date, of the substantive consolidation of the Debtors an12 their respective Estates into the Estate of Debtor FCI, solely for purposes of voting and distributionunder the Plan. Pursuant to the Confirmation Order, on and after the Effective Date, (i) a13 Distributable Assets to be used for distributions to Creditors of any of the Debtors will be treated athough they were merged into Liquidating Debtor FCI; and (ii) any obligation of any Debtor and a14 guarantees thereof executed by, or joint liability of, any of the Debtors will be treated as one obligatioof Liquidating Debtor FCI for distribution purposes pursuant to this Plan. 15 (b) Notwithstanding the foregoing, the substantive consolidation of the Debtors for votin16 and distribution purposes shall not affect or impair (i) any rights, Claims, remedies or defenses of (obetween) the separate Debtors as of the Petition Date, including with respect to any Retained Right17 of Action; (ii) the legal and organizational structure of the Debtors; (iii) any Liens that are maintainerecognized, or preserved under the Plan; and (iv) claims under or with respect to any insurance polic18 of any Debtor (or any right to the proceeds of any such policy or policies). 19 (c) The Disclosure Statement and the Plan shall be deemed to be a motion by the PlaProponents for substantive consolidation. Any objection by an affected Creditor to such consolidatio20 shall be treated as an objection to Confirmation and shall be determined by the Bankruptcy Court ithe context of considering Confirmation of the Plan. 21 (d) If the Bankruptcy Court determines that substantive consolidation of any give22 Debtor(s) is not appropriate, then the Plan Proponents may request that the Bankruptcy Couotherwise confirm the Plan and approve the treatment of and distributions to the different Classe23 under the Plan on an adjusted, Debtor-by-Debtor basis. Furthermore, the Plan Proponents reservtheir rights to seek Confirmation of the Plan without implementing substantive consolidation of an24 given Debtor, and, in the Plan Proponents’ discretion, to request that the Bankruptcy Court approvthe treatment of and distributions to any given Class under the Plan on an adjusted, Debtor-by-Debt25 basis. 26 (e) Notwithstanding the substantive consolidation called for herein, each and every Debtoshall remain responsible for the payment of U.S. Trustee fees pursuant to 28 U.S.C. § 1930 until it27 particular case is closed; provided, however, the Debtors or some of them may apply to close the caseof those Debtors following Confirmation. 28

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1 5.3 Continued Corporate Existence and Vesting of Assets. 2 (a) On and after the Effective Date, subject to the requirements of the Plan, the LiquidatinDebtors will continue to exist as separate corporations or limited liability companies (as applicable3 and shall retain all of the powers of corporations or limited liability companies (as applicable) undapplicable non-bankruptcy law, and without prejudice to any right to amend their respective operatin4 agreement, dissolve, merge or convert into another form of business entity, or to alter or terminattheir existence. The existing stock, membership and/or other equity interests (as applicable) of th5 Debtors shall be deemed to be held through the Plan Administrator. Further, the Debtors’ bylawoperating agreements, and/or other corporate governance documents (as applicable) shall be deeme6 to include a provision prohibiting the issuance of nonvoting equity securities and such other provisionas may be required pursuant to section 1123(a)(6) of the Bankruptcy Code. 7 (b) Except as otherwise provided in the Plan, on and after the Effective Date, a8 Distributable Assets and property of the Debtors and their Estates, including any interests isubsidiaries and affiliates and any Retained Rights of Action of the Debtors, will vest in Liquidatin9 Debtor FCI free and clear of all Claims, Liens, charges, other encumbrances and Interests. Neiththe occurrence of the Effective Date, nor the effectiveness of this Plan, nor any provision of applicabl10 non-bankruptcy law shall cause a dissolution of the Debtors, which shall be continued as corporationor limited liability companies (as applicable) following the Effective Date subject to the terms of th11 Plan. 12 (c) On and after the Effective Date, subject to the requirements of the Plan, the LiquidatinDebtors shall be permitted to conduct their business (to the extent permitted by the Plan), reconcil13 Claims, use and dispose of assets, prosecute litigation, make required tax filings, and otherwise takany and all actions as may be appropriate to implement the Plan without supervision by the Bankruptc14 Court and free of any restrictions under the Bankruptcy Code or the Bankruptcy Rules. ThLiquidating Debtors shall be authorized, without limitation, to use and dispose of the Distributabl15 Assets of the Debtors and their Estates, to investigate and pursue any Retained Rights of Action as threpresentative of the Debtors’ Estates pursuant to section 1123(b)(3)(B) of the Bankruptcy Code, t16 acquire and dispose of other property, and to otherwise administer their affairs. 17 5.4 Corporate Action; Winding Up of Affairs. 18 (a) On the Effective Date, the matters under the Plan involving or requiring, as applicablcorporate or limited liability company action of the members, managers, directors, or officers of th19 Debtors, including but not limited to actions requiring a vote or other approval of, as applicable, thboard of managers or board of directors or any of the members or officers of the Debtors or th20 execution of any documentation incident to or in furtherance of the Plan, shall be deemed to have beeauthorized by the Confirmation Order and to have occurred and be in effect from and after th21 Effective Date, without any further action by the Bankruptcy Court or the members, managerdirectors, or officers of the Debtors. 22 (b) Without limiting the generality of the foregoing, on the Effective Date an23 automatically and without further action, (i) any existing director, manager and officer of the Debtorwill be deemed to have resigned on the Effective Date without any further corporate action, (ii) th24 Plan Administrator shall be deemed the sole manager, director, officer and representative of thLiquidating Debtors to exercise the rights, power and authority of the Liquidating Debtors und25 applicable provisions of this Plan and bankruptcy and non-bankruptcy law, and (iii) all matterprovided under this Plan shall be deemed to be authorized and approved without further approval fro26 the Bankruptcy Court. The Confirmation Order shall modify the Debtors’ operating agreementbylaws and any other corporate governance documents such that the provisions of this Plan can b27 effectuated. The Plan shall be administered by the Plan Administrator, and all actions taken thereundein the name of the Liquidating Debtors shall be taken through the Plan Administrator. All corporat28 governance activities of the Liquidating Debtors shall be exercised by the Plan Administrator in his

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1 her discretion, subject to the terms of this Plan. 2 (c) Following the Confirmation Date, the Liquidating Debtors shall not engage in anbusiness activities or take any actions, except those necessary or appropriate to (i) effectuate the Pla3 and (ii) dispose of their assets and wind up the affairs of the Debtors and their Estates as soon areasonably practicable. On and after the Effective Date, the Plan Administrator may, in the name 4 the Liquidating Debtors, take such actions without supervision or approval by the Bankruptcy Couand free of any restrictions of the Bankruptcy Code or the Bankruptcy Rules, other than any restriction5 expressly imposed by the Plan or the Confirmation Order. Without limiting the foregoing, the PlaAdministrator may, without application to or approval of the Bankruptcy Court, pay, from the proceed6 of Distributable Assets, the charges that he or she incurs after the Effective Date for professional feeand expenses that, but for the occurrence of the Effective Date, would constitute Allowe7 Administrative Expenses. 8 (d) From and after the Effective Date, (i) the Debtors, for all purposes, shall be deemed thave withdrawn their business operations from any state or territory in which they were previousl9 conducting or are registered or licensed to conduct their business operations, and the Debtors shall nbe required to file any document, pay any sum or take any other action, in order to effectuate suc10 withdrawal, and (ii) the Debtors shall not be liable in any manner to any taxing authority for franchisbusiness, license or similar taxes accruing on or after the Effective Date. 11 (e) Pursuant to section 1146(c) of the Bankruptcy Code, any transfers effected pursuant t12 the Plan shall not be subject to any document recording tax, stamp tax, conveyance fee, intangibles similar tax, mortgage tax, stamp act, real estate transfer tax, mortgage recording tax or other simil13 tax or governmental assessment. 14 5.5 Plan Administrator. 15 (a) On the Effective Date, the Plan Administrator shall begin acting for the LiquidatinDebtors in the same fiduciary capacity as applicable to a board of directors of a Delaware corporatio16 implementing such liquidation and wind-down as contemplated under this Plan, subject to thprovisions hereof. The Plan Administrator shall serve in such capacity through the earlier of the dat17 that all of the Debtors are dissolved in accordance with this Plan and the date such Plan Administratoresigns, is terminated or otherwise unable to serve; provided, however, that any successor Pla18 Administrator appointed pursuant to the Plan shall serve in such capacity after the effective date such person’s appointment as Plan Administrator. 19 (b) The qualifications and proposed compensation of and other disclosures regarding th20 Plan Administrator shall be set forth as part of the Plan Supplement; such compensation may be paifrom the Liquidating Debtors’ Cash on hand, without further notice or order of the Bankruptcy Cour21 Further, the Plan Administrator shall be entitled to reimbursement, from the Liquidating Debtors’ Cason hand, for his or her actual, reasonable, and necessary expenses incurred in connection with th22 performance of his or her duties, without the need for further notice or Bankruptcy Court approvaAll distributions to be made to Creditors under the Plan shall be made by the Plan Administrator (o23 his or her designated agent). The Plan Administrator shall deposit and hold all Cash in trust for thbenefit of Creditors (including Professional Persons) receiving distributions under the Plan. The dutie24 and powers of the Plan Administrator shall include, without limitation, the following (without need ofurther Court approval): 25 (i)To exercise all power and authority that may be exercised, to commence a26 proceedings (including the power to continue any actions and proceedings that may have beecommenced by the Debtors prior to the Effective Date) that may be commenced, and to tak27 all actions that may be taken by any officer, director, or manager of the Liquidating Debtorwith like effect as if authorized, exercised, and taken by unanimous action of such officer28 directors, and managers, including consummating the Plan and all transfers thereunder o

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1 behalf of the Liquidating Debtors; 2 (ii)To wind up the affairs of the Liquidating Debtors and any or all of their subsidiarieand affiliates and their Estates to the extent appropriate as expeditiously as reasonably possibl3 (iii)To maintain all accounts, make distributions, and take other actions required und4 or consistent with the Plan, including the maintenance of appropriate reserves, in the name othe Liquidating Debtors; 5 (iv) To use, manage, sell, abandon, convert to Cash and/or otherwise dispose of th6 Distributable Assets for the purpose of liquidating or otherwise disposing of all remaininproperty of the Estates, making distributions and fully consummating this Plan; 7 (v) To take all steps necessary or appropriate to terminate the corporate existence o8 the Debtors consistent with this Plan; 9 (vi) To prosecute objections to Claims and Interests, and to compromise or settle anClaims or Interests (Disputed or otherwise); 10 (vii)To prosecute any and all Retained Rights of Action and compromise or settle an11 Retained Rights of Action; provided, however, the Plan Administrator will not, on behalf the Debtors and Liquidating Debtors, prosecute or otherwise pursue any Avoidance Claim12 after the Effective Date; 13 (viii)To prepare and file tax returns to the extent required by law;14 (ix)To employ and compensate any and all such professionals and agents as the PlaAdministrator, in his or her sole discretion, deems appropriate to perform his or her dutie15 under the Plan without further order of the Bankruptcy Court; and 16 (x)To take all other actions not inconsistent with the provisions of the Plan that thPlan Administrator deems reasonably necessary or desirable in connection with th17 administration of the Plan, including, without limitation, filing all motions, pleadings, reportand other documents in connection with the administration and closing of the Chapter 11 Case18 (c) The Plan Administrator may be removed by the Bankruptcy Court upon application f19 good cause shown. In the event of the resignation, removal, death, or incapacity of the PlaAdministrator, the Bankruptcy Court shall, upon motion or sua sponte, appoint another Person t20 become Plan Administrator, with notice thereof provided to the Post-Effective Date Service List. Ansuccessor Plan Administrator, without any further act, shall become fully vested with all of the right21 powers, duties, and obligations of his or her predecessor. 22 5.6 Source of Funding. The source of all distributions and payments under this Plan will be thDistributable Assets and the proceeds thereof, including, without limitation, the Debtors’ Cash on han23 and proceeds from any sale or other disposition of the Debtors’ remaining assets and prosecution Retained Rights of Action. 24 5.7 Retained Rights of Action. 25 (a) In accordance with section 1123(b) of the Bankruptcy Code, the Liquidating Debtor26 shall retain and may enforce all rights to commence and pursue, as appropriate, any and all RetaineRights of Action, whether arising before or after the Petition Date, including any actions specificall27 enumerated in the Plan Supplement, and the Liquidating Debtors’ rights to commence, prosecute, osettle such Retained Rights of Action shall be preserved notwithstanding the occurrence of th28 Effective Date. The Plan Administrator may pursue such Retained Rights of Action, as appropriat

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1 in accordance with the best interests of the Liquidating Debtors; provided, however, the PlaAdministrator will not, on behalf of the Debtors and Liquidating Debtors, prosecute or otherwis2 pursue any Avoidance Claims after the Effective Date. No Person may rely on the absence of specific reference in the Plan, the Plan Supplement, or the Disclosure Statement to any Retaine3 Right of Action against it as any indication that the Debtors or Liquidating Debtors, aapplicable, will not pursue any and all available Retained Rights of Action against it. Th4 Debtors or Liquidating Debtors, as applicable, expressly reserve all rights to prosecute any anall Retained Rights of Action against any Person, except as otherwise expressly provided in th5 Plan. Unless any Right of Action is expressly waived, relinquished, exculpated, releasecompromised, or settled in the Plan or a Bankruptcy Court order, the Debtors and the Liquidatin6 Debtors expressly reserve all Rights of Action for later adjudication, and, therefore, no preclusiodoctrine, including the doctrines of res judicata, collateral estoppel, issue preclusion, claim preclusio7 estoppel (judicial, equitable, or otherwise), or laches shall apply to such Retained Rights of Actioupon, after, or as a consequence of Confirmation or Consummation of the Plan. 8 (b) In accordance with section 1123(b)(3) of the Bankruptcy Code, any Retained Rights 9 Action shall vest in the Liquidating Debtors. The Liquidating Debtors shall have standing as threpresentative of the Debtors’ Estates pursuant to section 1123(b)(3)(B) of the Bankruptcy Code t10 pursue, or decline to pursue, the Retained Rights of Action and objections to Claims, as appropriatin the business judgment of the Plan Administrator. The Liquidating Debtors, acting through the Pla11 Administrator, may settle, release, sell, assign, otherwise transfer, or compromise Retained Rights oAction and/or objections to Claims without need for notice or order of the Bankruptcy Court. 12 5.8 Interests in Non-Debtors Affiliates and Subsidiaries. As of the Effective Date, except a13 expressly provided in the Plan or by separate order of the Bankruptcy Court, the Liquidating Debtorshall retain any stock or interests that they may hold in any non-Debtor affiliates or subsidiaries an14 retain any rights to which such stock or interests may be entitled under applicable law with respect tsuch shares or other interests. After the Effective Date, the Liquidating Debtors may sell, transfe15 assign or otherwise dispose of such shares or interests as permitted by applicable law. 16 5.9 Payment of Plan Expenses. The Liquidating Debtors may pay all reasonable Plan Expensewithout further notice to Creditors or Holders of Interests or approval of the Bankruptcy Court. 17 5.10 Dissolution of Debtors; Final Decree. Once the Plan Administrator determines that the Fin18 Resolution Date has occurred as to any of the Liquidating Debtors, such Liquidating Debtors shall bdissolved for all purposes by the Plan Administrator without the necessity for any other or furthe19 actions to be taken by or on behalf of any Liquidating Debtors or payments to be made in connectiotherewith; provided, however, that, without the need of any further approval, the Plan Administrat20 in his or her discretion may execute and file documents and take all other actions as he or she deemappropriate relating to the dissolution of the Liquidating Debtors under the laws of Delaware and/21 any other applicable states, and in such event, all applicable regulatory or governmental agencies shatake all steps necessary to allow and effect the prompt dissolution of the Liquidating Debtors a22 provided herein, without the payment of any fee, tax, or charge and without need for the filing ocertificates. At any time following the Effective Date, the Plan Administrator, on behalf of th23 Liquidating Debtors, shall be authorized to move for the entry of a final decree closing any or all othe Chapter 11 Cases pursuant to section 350 of the Bankruptcy Code. 24 5.11 Records. The Liquidating Debtors and Plan Administrator shall maintain reasonably goo25 and sufficient books and records of accounting relating to the Distributable Assets, the LiquidatinDebtors’ Cash, the management thereof, all transactions undertaken by such parties, all expense26 incurred by or on behalf of the Liquidating Debtors and Plan Administrator, and all distributioncontemplated or effectuated under this Plan. Upon the entry of a final decree closing the Chapter 127 Cases, unless otherwise ordered by the Bankruptcy Court, the Liquidating Debtors and PlaAdministrator may destroy or otherwise dispose of all records maintained by the Liquidating Debtor28 and/or Plan Administrator. Notwithstanding anything to the contrary, the Plan Administrator ma

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1 upon notice to the Post-Effective Date Service List and without Bankruptcy Court approval, destroany documents that he or she believes are no longer required to effectuate the terms and conditions 2 this Plan. 3 ARTICLE VI 4 TREATMENT OF EXECUTORY CONTRACTS AND UNEXPIRED LEASES 5 6.1 Rejection of Executory Contracts and Unexpired Leases. Except for any executorcontracts or unexpired leases: (i) that previously were assumed, assumed and assigned, or rejected b6 an order of the Bankruptcy Court, pursuant to section 365 of the Bankruptcy Code; (ii) that are listefor assumption by the Debtors as of the Effective Date in a Plan Supplement to be filed and served o7 affected non-Debtor counterparties; (iii) as to which a motion for approval of the assumption rejection of such contract or lease has been Filed and served prior to the Effective Date; (iv) th8 constitute contracts of insurance in favor of, or that benefit, the Debtors or the Estates; or (v) that werpreviously sold, conveyed or otherwise assigned pursuant to Final Order, each executory contract an9 unexpired lease entered into by the Debtors prior to the Petition Date that has not previously expireor terminated pursuant to its own terms shall be deemed rejected pursuant to section 365 of th10 Bankruptcy Code as of the Effective Date. Without limiting the foregoing, the indemnificatioobligations in favor of the Debtors’ current directors, officers, managers, and representatives, to th11 extent not previously rejected, shall be assumed as of the Effective Date, and all other pre-EffectivDate indemnification obligations of the Debtors shall be deemed rejected as of the Effective Date t12 the extent that such obligations are contained in executory contracts within the meaning of section 36of the Bankruptcy Code, but only to the extent not inconsistent with any existing insurance obligation13 The Confirmation Order shall constitute an order of the Bankruptcy Court approving such assumptionor rejections, pursuant to section 365 of the Bankruptcy Code, as of the Effective Date. 14 6.2 Bar Date for Rejection Claims. If the rejection of an executory contract or unexpired leas15 pursuant to the Plan or otherwise gives rise to a Claim by the other party or parties to such contract olease, such Claim shall be forever barred and shall not be enforceable against the Debtors or thei16 Estates unless a proof of Claim is Filed and served on the Plan Administrator and its counsel withithirty (30) calendar days after the earlier of (a) the Effective Date and (b) service of a notice that th17 executory contract or unexpired lease has been rejected. All such Claims for which proofs of Claiare required to be Filed, if Allowed, will be, and will be treated as, General Unsecured Claims, subje18 to the provisions of the Plan. 19 ARTICLE VII 20 DISTRIBUTIONS AND RELATED MATTERS 21 7.1 Dates of Distribution. Whenever any payment or distribution to be made under the Plan shabe due on a day other than a Business Day, such payment or distribution shall instead be made, witho22 interest, by the Liquidating Debtors (or their agent) on the immediately following Business Day. 23 7.2 Cash Distributions. Distributions of Cash may be made either by check drawn on a domestibank or wire or ACH transfer from a domestic bank, at the option of the Liquidating Debtors, exce24 that Cash payments made to foreign Creditors may be made in such funds and by such means as arnecessary or customary in a particular foreign jurisdiction. 25 7.3 Rounding of Payments. Whenever payment of a fraction of a cent would otherwise be calle26 for, the actual payment shall reflect a rounding down of such fraction to the nearest whole cent. Tthe extent Cash remains undistributed as a result of the rounding of such fraction to the nearest whol27 cent, such Cash shall be treated as “Unclaimed Property” under the Plan. 28 7.4 Disputed Claims. Notwithstanding all references in the Plan to Claims that are Allowe

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1 solely for the purpose of calculating (but not distributing) the amount or number of distributions to bmade on account of Allowed Class 3 General Unsecured Claims under the Plan, such calculations ma2 be made, in the Plan Administrator’s sole discretion, as if each Disputed Claim were an Allowed Claiexcept that if the Bankruptcy Court estimates the likely portion of a Disputed Claim to be Allowed 3 authorized or otherwise determines the amount or number which would constitute a sufficient reservfor a Disputed Claim (which estimates and determinations may be requested by the Liquidatin4 Debtors), such amount or number as determined by the Bankruptcy Court may be used for calculationas to such Disputed Claim instead. 5 7.5 Undeliverable and Unclaimed Distributions. In the event that any distribution to any Holde6 is returned as undeliverable, no distribution to such Holder shall be made unless and until the PlaAdministrator has determined the then current address of such Holder, at which time such distributio7 shall be made to such Holder without interest; provided, however, that such distributions shall bdeemed Unclaimed Property at the expiration of ninety (90) calendar days from the date of suc8 attempted distribution. After such date, all Unclaimed Property shall revert to the Liquidating Debtorautomatically and without need for a further order by the Bankruptcy Court (notwithstanding an9 applicable federal, provincial, or state escheat, abandoned or unclaimed property laws to the contraryand the Claim of any Holder to such property or Interest in property shall be forever barred. The Pla10 Administrator may implement reasonable attempts to reach any recipient of an undeliverabldistribution prior to reverting such property to the Liquidating Debtors. 11 7.6 Minimum Distributions. Notwithstanding any other provision of the Plan, in the Pla12 Administrator’s sole discretion, the Plan Administrator will not be required to make distributions Cash less than $25 in value, and each such Claim to which this limitation applies shall be deemed full13 and finally satisfied and not entitled to any further payment or consideration pursuant to Article Iand its Holder is forever barred pursuant to Article IX from asserting that Claim or Claims against th14 Debtors, the Liquidating Debtors, their Estates, or their property. 15 7.7 Compliance With Tax Requirements. 16 (a) The Liquidating Debtors shall comply with all withholding and reporting requirementimposed by federal, state, or local taxing authorities in connection with making distributions pursua17 to the Plan. 18 (b) In connection with each distribution with respect to which the filing of an informatioreturn (such as an IRS Form 1099 or 1042) or withholding is required, the Liquidating Debtors sha19 file such information return with the IRS and provide any required statements in connection therewitto the recipients of such distribution, or effect any such withholding and deposit all moneys so withhel20 to the extent required by law. With respect to any Person from whom a tax identification numbecertified tax identification number or other tax information required by law to avoid withholding ha21 not been received, the Liquidating Debtors may, in their sole option, withhold the amount requireand distribute the balance to such Person or decline to make such distribution until the information i22 received. 23 7.8 Record Date in Respect to Distributions. Except as set forth below, the record date and timfor the purpose of determining which Persons are entitled to receive any and all distributions o24 account of any Allowed Claims or Interests, irrespective of the date of or number of distributions, shabe the Record Date. 25 ARTICLE VIII 26 LITIGATION, OBJECTIONS TO CLAIMS, AND DETERMINATION OF TAXES 27 28 8.1 Litigation. Except as may be expressly provided otherwise in the Plan, the Liquidatin

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1 Debtors, through the Plan Administrator, shall be responsible for pursuing Retained Rights of Actioany objection to the allowance of any Claim, and the determination of tax issues and liabilities. 2 8.2 Objections to Claims; Objection Deadline. As of the Effective Date, the Liquidating Debtor3 shall be authorized to file objections, settle, compromise, withdraw or litigate to judgment objectionto Claims. Any objection to a Claim shall be filed with the Bankruptcy Court and served on the Perso4 holding such Claim within one hundred eighty (180) calendar days after the Effective Date (as mabe extended pursuant to this section, the “Objection Deadline”), provided that the Liquidating Debtor5 may seek one or more extensions thereof subject to Bankruptcy Court approval and with notice onlto parties that have requested such notice pursuant to Bankruptcy Rule 2002. 6 8.3 Tax Determinations. In addition to any other available remedies or procedures with respe7 to Tax issues or liabilities or rights to tax refunds, the Liquidating Debtors, at any time, may utiliz(and receive the benefits of) section 505 of the Bankruptcy Code with respect to: (1) any tax issue 8 liability or right to a tax refund relating to an act or event occurring prior to the Effective Date; or (any tax liability or right to a tax refund arising prior to the Effective Date. If the Liquidating Debtor9 utilize section 505(b) of the Bankruptcy Code: (1) the Bankruptcy Court shall determine the amouof the subject Tax liability or right to a Tax refund in the event that the appropriate Governmental Un10 timely determines a Tax to be due in excess of the amount indicated on the subject return; and (2) the prerequisites are met for obtaining a discharge of Tax liability in accordance with section 505(11 of the Bankruptcy Code, the Liquidating Debtors shall be entitled to such discharge which shall applto any and all Taxes relating to the period covered by such return. 12 8.4 Temporary or Permanent Resolution of Disputed Claims. The Liquidating Debtors ma13 request that the Bankruptcy Court estimate any contingent or unliquidated Disputed Claim pursuato section 502(c) of the Bankruptcy Code, irrespective of whether any Person has previously objecte14 to such Disputed Claim. The Bankruptcy Court will retain jurisdiction and power to estimate ancontingent or unliquidated Disputed Claim at any time. If the Bankruptcy Court estimates an15 contingent or unliquidated Disputed Claim, that estimated amount will constitute either the Alloweamount of such Disputed Claim or a maximum limitation on such Disputed Claim, as determined b16 the Bankruptcy Court. If the estimated amount constitutes a maximum limitation on such DisputeClaim, then the Liquidating Debtors may elect to pursue any supplemental proceedings to object t17 any ultimate payment on account of such Disputed Claim. In addition, the Liquidating Debtors maresolve or adjudicate any Disputed Claim in the manner in which the amount of such Claim or Intere18 and the rights of the Holder of such Claim or Interest would have been resolved or adjudicated if thChapter 11 Cases had not been commenced. All of the aforementioned objection, estimation an19 resolution procedures are cumulative and not necessarily exclusive of one another. 20 8.5 Setoffs. The Liquidating Debtors may, but shall not be required to, setoff against any Claiand the payments or other distributions to be made pursuant to the Plan in respect of such Claim ma21 be setoff against claims of any nature whatsoever that the Debtors or the Estates may have against thHolder of such Claim; provided, however, that neither the failure to do so nor the allowance of an22 Claim hereunder shall constitute a waiver or release by the Liquidating Debtors of any such claim ththe Liquidating Debtors may have against such Holder, unless otherwise agreed to in writing by suc23 Holder and the Liquidating Debtors. 24 ARTICLE IX 25 INJUNCTIONS, EXCULPATION, RELEASES AND RELATED PROVISIONS 26 9.1 Injunctions. 27 9.1.1 Generally. Unless otherwise provided in the Plan or the Confirmation Order, all injunctionand stays provided for in the Chapter 11 Cases pursuant to sections 105 and 362 of the Bankruptc28 Code or otherwise in effect on the Confirmation Date, shall remain in full force and effect until th

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1 Effective Date. From and after the Effective Date, all Persons are permanently enjoined from, anrestrained against, commencing or continuing in any court any suit, action or other proceeding, o2 otherwise asserting any claim or interest, seeking to hold (i) the Liquidating Debtors or their Estateor (ii) the property of the Debtors or their Estates, liable for any Claim, obligation, right, interest, de3 or liability that has been released pursuant to the Plan. 4 9.1.2 Non-Discharge of Debtors; Injunction. In accordance with section 1141(d)(3) of thBankruptcy Code, this Plan does not discharge the Debtors. Section 1141(c) of the Bankruptc5 Code nevertheless provides, among other things, that the property dealt with by the Plan is freand clear of all Claims and Interests against the Debtors. As such, no Person may receive an6 payment from, or seek recourse against, any assets that are to be distributed under this Plaother than assets required to be distributed to that Person under the Plan. As of the Effectiv7 Date, all parties are precluded from asserting against any property to be distributed under thiPlan any Claims, rights, causes of action, liabilities, or Interests based upon any act, omissio8 transaction, or other activity that occurred before the Effective Date except as expresslprovided in this Plan or the Confirmation Order. 9 9.2 Exculpation. As of and subject to the occurrence of the Effective Date, for good an10 valuable consideration, including the consideration provided under the Plan, the ExculpateParties shall neither have nor incur any liability to any Person for any act taken or omitted t11 be taken, on or after the Petition Date, in connection with, or related to, the formulatiopreparation, dissemination, implementation, administration, Confirmation or Consummatio12 of the Plan or any contract, instrument, waiver, release or other agreement or document createor entered into, in connection with the Plan, or any other act taken or omitted to be taken i13 connection with the Chapter 11 Cases or the Debtors up to and including the Effective Datprovided, however, that the foregoing provisions of this subsection shall have no effect on th14 liability of any Person that results from any such act or omission that is determined in a FinOrder to have constituted willful misconduct or actual fraud. For the avoidance of doubt, th15 scope of the exculpation provided under this Section 9.2 does not include any of the current oformer members of the Debtors or any of the former directors, officers, managers an16 representatives of the Debtors who did not serve in such capacities during the Chapter 11 Caseor a portion thereof. Notwithstanding anything in the Plan to the contrary, no Person servin17 as Plan Administrator shall have or incur any personal liability as the manager, membedirector or officer of the Debtors or Liquidating Debtors for any act taken or omission made i18 connection with the wind-up or dissolution of the Liquidating Debtors or any nondebtosubsidiary or affiliate; provided, however, that the foregoing shall have no effect on the liabilit19 of the Plan Administrator that results from any such act or omission that is determined in Final Order to have constituted willful misconduct or actual fraud. 20 9.3 Debtor Release. As of and subject to the occurrence of the Effective Date, for good an21 valuable consideration, the Debtors, for themselves and the Estates, hereby irrevocablunconditionally and generally release the Released Parties from any and all claims, obligation22 rights, suits, damages, causes of action, and liabilities, whether known or unknown, foreseen ounforeseen, liquidated or unliquidated, fixed or contingent, matured or unmatured, in law o23 equity or otherwise, which the Debtors or their Estates ever had, now have or hereafter cashall or may have against any of the Released Parties from the beginning of time to the Effectiv24 Date that in any way relate to the Debtors, their direct or indirect non-Debtor subsidiaries, thEstates, or the Chapter 11 Cases; provided, however, that the foregoing provisions of thi25 subsection shall have no effect on the liability of any Person that results from any such act oomission that is determined in a Final Order to have constituted willful misconduct or actu26 fraud. For the avoidance of doubt, the scope of the release provided under this Section 9.3 doenot include any of the current or former members of the Debtors or any of the former director27 officers, managers and representatives of the Debtors who did not serve in such capacities durinthe Chapter 11 Cases or a portion thereof. 28

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1 9.4 Consenting Creditor Release. As of and subject to the occurrence of the Effective Datand except for the treatment provided in the Plan, for good and valuable consideration eac2 Releasing Creditor, for itself and its respective present or former officers, directors, managershareholders, trustees, partners and partnerships, members, agents, employees, representative3 attorneys, accountants, professionals, and successors or assigns, in each case solely in theicapacity as such, shall be deemed to have completely, conclusively, unconditionally an4 irrevocably released the Released Debtor/Committee Parties from any and all claimobligations, rights, suits, damages, causes of action, and liabilities, whether known or unknow5 foreseen or unforeseen, liquidated or unliquidated, fixed or contingent, matured or unmaturein law or equity or otherwise, which the Releasing Creditor, the Debtors or their Estates eve6 had, now have or hereafter can, shall or may have against any of the Released Debtor/CommitteParties from the beginning of time to the Effective Date that in any way relate to the Debtor7 their direct or indirect non-Debtor subsidiaries, the Estates, or the Chapter 11 Cases, providehowever, that the foregoing release does not affect or impair any obligations under an8 intercreditor agreements or any other agreements or arrangements between and among nonDebtor parties. For the avoidance of doubt, the Released Debtor/Committee Parties do n9 include any of the current or former non-Debtor members of the Debtors or any formedirectors, officers, managers and representatives of the Debtors who did not serve in suc10 capacities during the Chapter 11 Cases or a portion thereof. 11 ARTICLE X 12 RETENTION OF JURISDICTION AND POWER 13 10.1 Retention of Jurisdiction. Notwithstanding the entry of the Confirmation Order or thoccurrence of the Effective Date, the Bankruptcy Court shall retain jurisdiction and power over th14 Chapter 11 Cases and any of the proceedings related to the Chapter 11 Cases pursuant to section 114of the Bankruptcy Code and 28 U.S.C. § 1334 to the fullest extent permitted by applicable la15 including, without limitation, such jurisdiction and power as appropriate to ensure that the purposand intent of the Plan are carried out. Without limiting the generality of the foregoing, the Bankruptc16 Court shall retain jurisdiction and power for the following purposes: 17 (a)establish the priority or secured or unsecured status of, allow, disallow, determine, liquidatclassify, or estimate any Claim or Interest (including, without limitation and by example onl18 determination of Tax issues or liabilities in accordance with section 505 of the Bankruptcy Coderesolve any objections to the allowance, priority, or secured or unsecured status of Claims or Interest19 or resolve any dispute as to the treatment necessary to reinstate a Claim or Interest pursuant to thPlan, including but not limited to determining whether any Creditor has a valid lien against any of th20 Debtors’ assets; 21 (b) grant or deny any applications for allowance of compensation or reimbursement oexpenses authorized pursuant to the Bankruptcy Code or the Plan, for periods ending on or before th22 Effective Date; 23 (c) resolve any matters related to the rejection of any executory contract or unexpired lease twhich any of the Debtors is a party or with respect to which any of the Debtors may be liable, and t24 hear, determine and, if necessary, liquidate any Claims arising therefrom; 25 (d)ensure that distributions to Holders of Allowed Claims are made pursuant to the provisionof the Plan, and to effectuate performance of the provisions of the Plan; 26 (e) decide or resolve any motions, adversary proceedings, contested or litigated matters an27 any other matters and grant or deny any applications involving any of the Debtors that may be pendinbefore the Effective Date or that may be commenced thereafter as provided in the Plan; 28

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1 (f) enter such orders as may be necessary or appropriate to implement or consummate thprovisions of the Plan and all contracts, instruments, releases, indentures and other agreements 2 documents created in connection with the Plan, the Disclosure Statement or the Confirmation Ordeexcept as otherwise provided in the Confirmation Order or in the Plan, including, without limitatio3 any stay orders as may be appropriate in the event that the Confirmation Order is for any reasoreversed, stayed, revoked, modified, supplemented or amended; 4 (g) resolve any cases, controversies, suits or disputes that may arise in connection with th5 consummation, interpretation or enforcement of the Plan, the Confirmation Order, or any other ordeof the Bankruptcy Court; 6 (h) subject to the restrictions on modifications provided in any contract, instrument, releas7 indenture or other agreement or document created in connection with the Plan, modify the Plan beforor after the Effective Date pursuant to section 1127 of the Bankruptcy Code or modify the Disclosur8 Statement, the Confirmation Order or any contract, instrument, release, indenture or other agreemeor document created in connection with the Plan, the Disclosure Statement or the Confirmation Orde9 or remedy any defect or omission or reconcile any inconsistency in any Bankruptcy Court order, thPlan, the Disclosure Statement, the Confirmation Order or any contract, instrument, release, indentur10 or other agreement or document created in connection with the Plan, the Disclosure Statement or thConfirmation Order, in such manner as may be necessary or appropriate to consummate the Plan, t11 the extent authorized by the Bankruptcy Code; 12 (i) issue injunctions, enter and implement other orders or take such other actions as may bnecessary or appropriate to restrain interference by any Person with the consummatio13 implementation or enforcement of the Plan or the Confirmation Order; 14 (j) consider and act on the compromise and settlement of any Claim or Retained Right oAction; 15 (k)decide or resolve any Retained Rights of Action; 16 (l)enter such orders as may be necessary or appropriate in connection with the recovery of th17 assets of the Liquidating Debtors wherever located; 18 (m)hear and decide any objections to Claims brought by the Liquidating Debtors or any otheparty in interest, to the extent authorized by the Plan; 19 (n)hear and decide any litigation, as applicable, brought by the Liquidating Debtors;20 (o) hear and determine any motions or contested matters involving Priority Tax Claims o21 Taxes either arising prior (or for periods including times prior) to the Effective Date or relating to thadministration of the Chapter 11 Cases, including, without limitation (i) matters involving federa22 state, and local Taxes in accordance with sections 346, 505 and 1146 of the Bankruptcy Code, (imatters concerning Tax refunds due for any period including times prior to the Effective Date, and (ii23 any matters arising prior to the Effective Date affecting Tax attributes of any of the Debtors; 24 (p) determine such other matters as may be provided for in the Confirmation Order or as mafrom time to time be authorized under the provisions of the Bankruptcy Code or any other applicabl25 law; 26 (q) enforce all orders, judgments, injunctions, releases, exculpations, indemnifications, anrulings issued or entered in connection with the Chapter 11 Cases or the Plan, including any ord27 approving any stipulation or settlement in the Chapter 11 Cases; 28 (r) remand to state court any claim, cause of action, or proceeding involving the Debtors th

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1 was removed to federal court, in whole or in part in reliance upon 28 U.S.C. § 1334; 2 (s) determine any other matters that may arise in connection with or relate to the Plan, thDisclosure Statement, the Confirmation Order or any contract, instrument, release, indenture or oth3 agreement or document created in connection with the Plan, the Disclosure Statement or thConfirmation Order, except as otherwise provided in the Plan; 4 (t) determine any other matter not inconsistent with the Bankruptcy Code; and5 (u)enter an order or final decree concluding the Chapter 11 Cases. 6 10.2 Failure of the Bankruptcy Court to Exercise Jurisdiction. If the Bankruptcy Court abstain7 from exercising, or declines to exercise, jurisdiction or is otherwise without jurisdiction over anmatter arising in, arising under, or related to the Chapter 11 Cases, including the matters set fort8 immediately above, the provisions of this Article X shall have no effect on, and shall not control, limior prohibit the exercise of jurisdiction by any other court having competent jurisdiction with respe9 to, such matter. 10 ARTICLE XI 11 MISCELLANEOUS PROVISIONS 12 11.1 Headings. The headings used in the Plan are inserted for convenience only and neithconstitute a portion of the Plan nor in any manner affect the construction of the provisions of the Pla13 11.2 Bar Date for Administrative Expenses. Requests for payment of all Administrativ14 Expenses, other than for which a request and/or proof of Claim has previously been filed, mube Filed and served on the Liquidating Debtors and the U.S. Trustee by no later than thirty (315 calendar days after the Effective Date. The Liquidating Debtors shall have until the ObjectioDeadline to object to a Timely Filed request for payment of an Administrative Expense (as ma16 be extended), provided, that, the Liquidating Debtors may seek extension(s) thereof subject tBankruptcy Court approval and with notice only to parties that have requested such notic17 pursuant to Bankruptcy Rule 2002. Nothing in the Plan shall prohibit the Liquidating Debtorfrom paying Administrative Expenses in the ordinary course in accordance with applicable la18 during or after the Chapter 11 Cases. 19 11.3 Professional Fee Claims. Notwithstanding the foregoing provisions of this Article XI, buexcept as may be expressly provided in other sections of the Plan, Professional Person20 requesting compensation or reimbursement of expenses incurred after the Petition Date anprior to the Effective Date must file and serve, on all parties entitled to notice thereof, a Fe21 Application for final allowance of compensation and reimbursement of expenses no later thathirty (30) calendar days after the Effective Date and any objections to such applications mu22 be made in accordance with applicable rules of the Bankruptcy Court. Professional Fee Claimshall be paid in accordance with the terms of the order(s) authorizing such payments a23 promptly as possible on the Effective Date for any outstanding amounts due as of the EffectivDate, and as soon as practicable thereafter as such obligation to pay becomes due unles24 otherwise agreed upon by the applicable Professional. From and after the Effective Date, thLiquidating Debtors shall in the ordinary course of business and without the necessity for an25 approval by the Bankruptcy Court, pay the reasonable fees and expenses of professionalthereafter incurred by the Liquidating Debtors. 26 11.4 Non-Voting Equity Securities. If and to the extent applicable, the Debtors shall comply wit27 the provisions of section 1123(a)(6) of the Bankruptcy Code. 28 11.5 Subordination Agreements. Pursuant to section 510(a) of the Bankruptcy Code, to the exte

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1 there is any subordination agreement in place between creditors that is enforceable under nonbankruptcy law, the Liquidating Debtors shall honor such subordination agreement and turn over an2 distributions required to be turned over pursuant to the terms of such agreements. 3 11.6 Notices. All notices and requests in connection with the Plan shall be in writing and shall bhand delivered or sent by mail, e-mail, or facsimile addressed to. 4 Plan Administrator: 5 mailto:Brad Smith Glass Ratner 6 555 W. 5th Street, Suite 3725 Los Angeles, CA 90013 7 Email: bsmith@glassratner.com 8 Debtors’ Counsel: SHULMAN BASTIAN FRIEDMAN & BUI LLP 9 Attn: Alan J. Friedman 10 100 Spectrum Center Drive, Suite 600 Irvine, California 92618 11 Telephone: (949) 340-3400 Facsimile: (949) 340-3000 12 Email: afriedman@shulmanbastian.com 13 Committee Counsel: 14 PACHULSKI STANG ZIEHL & JONES LLP Attn: Jeffrey W. Dulberg 15 10100 Santa Monica Blvd., 13th Floor Los Angeles, CA 90067 16 Telephone: (310) 277-6910 Facsimile: (310) 201-0760 17 Email: jdulberg@pszjlaw.com 18 All notices and requests to any Person of record holding any Claim or Interest shall be sent to suc19 Person at the Person’s last known address or to the last known address of the Person’s attorney orecord. Any such Person may designate in writing any other address for purposes of this section o20 the Plan, which designation will be effective on receipt. 21 11.7 Successors and Assigns. The rights, duties and obligations of any Person named or referreto in the Plan shall be binding upon, and shall inure to the benefit of, the successors and assigns 22 such Person. 23 11.8 Severability of Plan Provisions. If, prior to Confirmation, any non-material term or provisioof the Plan is held by the Bankruptcy Court to be invalid, void or unenforceable, the Bankruptcy Cou24 will have the power to alter and interpret such term or provision to make it valid or enforceable to thmaximum extent practicable, consistent with the original purpose of the term or provision held to b25 invalid, void or unenforceable, and such term or provision will then be applicable as altered ointerpreted. Notwithstanding any such holding, alteration or interpretation, the remainder of the term26 and provisions of the Plan will remain in full force and effect and will in no way be affected, impaireor invalidated by such holding, alteration or interpretation. The Confirmation Order will constitute 27 judicial determination that each term and provision of the Plan, as it may have been altered ointerpreted in accordance with the foregoing, is valid and enforceable pursuant to their terms. 28

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1 11.9 No Waiver. Neither the failure of the Debtors to list a Claim in the Debtors’ Schedules, thfailure of the Debtors to object to any Claim or Interest for purposes of voting, the failure of th2 Debtors to object to a Claim or Interest prior to Confirmation or the Effective Date, the failure of thDebtors to assert a Retained Right of Action prior to Confirmation or the Effective Date, the absenc3 of a proof of Claim having been filed with respect to a Claim, nor any action or inaction of the Debtoror any other Person with respect to a Claim, Interest or Retained Right of Action other than a legall4 effective express waiver or release shall be deemed a waiver or release of the right of the LiquidatinDebtors or their successors, before or after solicitation of votes on the Plan or before or afte5 Confirmation or the Effective Date, to (a) object to or examine such Claim or Interest, in whole or ipart or (b) retain and either assign or exclusively assert, pursue, prosecute, utilize, otherwise act 6 otherwise enforce any Rights of Action. 7 11.10 Inconsistencies. In the event the terms or provisions of the Plan are inconsistent with the termand provisions of the exhibits to the Plan or documents executed in connection with the Plan, the term8 of the Plan shall control; provided, however, that the Confirmation Order shall control and takprecedence in the event of any inconsistency between the Confirmation Order, any provision of th9 Plan, and any of the foregoing documents. 10 11.11 Plan Supplement. No later than ten (10) calendar days prior to the deadline to vote on thiPlan, the Plan Proponents shall File with the Bankruptcy Court the Plan Supplement, which sha11 contain such substantially final agreements, other documents and information as may be necessary oappropriate to effectuate and further evidence the terms and conditions of the Plan. Holders of Claim12 or Interests may obtain a copy of the Plan Supplement upon written request to the Debtors or thCommittee. 13 11.12 Preservation of Insurance. The Debtors’ release from and payment of Claims as provided i14 the Plan shall not diminish or impair the enforceability of any insurance policy that may cover otherwise apply to or regarding any Claims, including, without limitation, any Claims on account o15 the Debtors’ officers or managers. 16 11.13 Waiver of Stay. The Plan Proponents request as part of the Confirmation Order a waiver the fourteen (14) day stay of Bankruptcy Rule 3020(e) and, to the extent applicable, a waiver of th17 fourteen (14) day stay of Bankruptcy Rule 6004(h). 18 11.14 Choice of Law. Except to the extent a rule of law or procedures is supplied by federal la(including but not limited to the Bankruptcy Code and the Bankruptcy Rules), this Plan shall b19 governed by, and construed in accordance with, the laws of the State of Delaware applicable tcontracts executed in and to be performed in that State. Any applicable non-bankruptcy law that woul20 prohibit, limit, or otherwise restrict implementation of the Plan based on (i) the commencement of thChapter 11 Cases, (ii) the appointment of the Plan Administrator, (iii) the wind down of the Debtor21 or (iv) any other act or action to be done pursuant to or contemplated by the Plan is superseded anrendered inoperative by the Plan and federal bankruptcy law. 22 11.15 Modification or Withdrawal of Plan. 23 (a) The Plan Proponents may jointly seek to amend or modify the Plan at any time prior t24 its Confirmation in the manner provided by section 1127 of the Bankruptcy Code or as otherwispermitted by law without additional disclosure pursuant to section 1125 of the Bankruptcy Cod25 except as the Bankruptcy Court may otherwise order, and except as otherwise set forth herein, the PlaProponents reserve the right to jointly amend the terms of the Plan or waive any conditions to it26 Confirmation, effectiveness or consummation, if the Plan Proponents jointly determine that sucamendments or waivers are necessary or desirable to confirm, effectuate or consummate the Plan. 27 (b) After Confirmation of the Plan, but prior to the Effective Date, the Plan Proponent28 may, pursuant to section 1127 of the Bankruptcy Code, seek to jointly modify the Plan. After th

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1 Effective Date, the Liquidating Debtors may apply to the Bankruptcy Court to remedy defects omissions in the Plan or to reconcile inconsistencies in the Plan. 2 (c) The Debtors and the Committee each reserve the right to revoke and withdraw the Pla3 at any time prior to the Effective Date, in which case the Plan will be deemed to be null and void. either the Debtors or the Committee revoke or withdraw the Plan, or if Confirmation or the Effectiv4 Date does not occur, then: (i) the Plan shall be null and void in all respects; (ii) any settlement compromise embodied in the Plan, assumption or rejection of executory contracts or unexpired lease5 affected by the Plan, and any document or agreement executed pursuant to the Plan, shall be deemenull and void; and (iii) nothing contained in the Plan shall: (a) constitute a waiver or release of an6 Claims or Interests or Rights of Action of the Debtors or the Estates against any other Person; (bprejudice in any manner the rights of the Debtors, the Estates, the Committee, or any other Person; 7 (c) constitute an admission, acknowledgement, offer or undertaking of any sort by the Debtors, thEstates, the Committee, or any other Person. 8 ARTICLE XII 9 CONDITIONS TO EFFECTIVENESS 10 12.1 Conditions to Effectiveness. The Plan will not be consummated and the Effective Date winot occur unless and until (A) the Confirmation Order is entered in a form acceptable to the Debtor11 and the Committee; (B) all documents to be provided in the Plan Supplement are in form and substancacceptable to the Debtors and the Committee; (C) the Confirmation Order shall be a Final Order; (D12 the Debtors and the Committee determine in their respective reasonable business judgment that thEstates have sufficient Cash to pay all Allowed Administrative Expenses, Allowed Priority Ta13 Claims and Allowed Priority Non-Tax Claims, as of the Effective Date, to the extent the Holderthereof are entitled to payment as of such date under the Plan and unless otherwise agreed by suc14 Holders, (E) the Debtors and the Committee determine in their respective reasonable businesjudgment that the Estates have sufficient Cash to pay all asserted, accrued, and estimate15 Administrative Expenses that have not yet been Allowed or are otherwise not yet payable as of thEffective Date but which such Administrative Expenses are anticipated to be later Allowed o16 otherwise payable and the Holders of any such Administrative Expenses have not agreed to alternativtreatment; and (F) a reserve has been established for Professional Fee Claims reasonably estimated b17 Professional Persons to become due and owing on account of services provided on or before thEffective Date. Any of the foregoing conditions may be jointly waived by the Debtors and th18 Committee and such waiver shall not require any notice, Bankruptcy Court order, or any further actioIn the event the foregoing conditions are not either satisfied or waived as provided herein, the Pla19 Proponents will seek to convert the Chapter 11 Cases to cases under chapter 7 of the Bankruptcy Cod20 ARTICLE XIII EFFECT OF CONFIRMATION 21 13.1 Binding Effect of Confirmation. Confirmation will bind the Debtors, the Committee, aHolders of Claims or Interests and other parties in interest to the provisions of the Plan whether or n22 the Claim or Interest of such Holder is Impaired under the Plan and whether or not the Holder of sucClaim or Interest has accepted the Plan. 23 13.2 Good Faith. Confirmation of the Plan shall constitute a conclusive determination that: (i) th24 Plan has been proposed in good faith and in compliance with applicable provisions of the BankruptcCode; and (ii) all Persons’ solicitations of acceptances or rejections of the Plan and the offer, issuanc25 sale, or purchase of a security offered or sold under the Plan have been in good faith and in compliancwith applicable provisions of the Bankruptcy Code and, in each case, that the Plan Proponents an26 their respective representatives have acted in good faith in connection therewith. 27 13.3 No Limitations on Effect of Confirmation. Nothing contained in the Plan will limit the effeof Confirmation as described in section 1141 of the Bankruptcy Code. 28

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1 ARTICLE XIV 2 CONFIRMATION REQUEST AND RECOMMENDATION 3 14.1 Request for Confirmation. The Plan Proponents jointly request that the Bankruptcy Couconfirm the Plan and that it do so, if applicable, pursuant to section 1129(b) of the Bankruptcy Cod4 notwithstanding the rejection of the Plan by any Impaired Class. 5 14.2 Recommendation for Confirmation. The Plan Proponents believe that confirmation animplementation of the Plan are the best alternative under the circumstances and urge all Impaire 6 Creditors entitled to vote on the Plan to vote in favor of and support Confirmation of the Plan. 7 8 May _5__, 2021 9 Brad Smith 10 CRO of Debtors and Debtors in Possession 11 May ____, 2021 12 13 ________________ Authorized Representative of 14 Official Committee of Unsecured Creditors 15 Submitted by: 16 Debtors’ Counsel 17 Alan J. Friedman (Bar No. 132580) SHULMAN BASTIAN FRIEDMAN & BUI LLP 18 100 Spectrum Center Drive, Suite 600 Irvine, California 92618 19 Telephone: (949) 340-3400 Facsimile: (949) 340-3000 20 Email: afriedman@shulmanbastian.com 21 -and- 22 Committee Counsel 23 Robert J. Feinstein (Pro Hac Vice) Jeffrey W. Dulberg (Bar No. 181200) 24 PACHULSKI STANG ZIEHL & JONES LLP 10100 Santa Monica Blvd., 13th Floor 25 Los Angeles, CA 90067 Telephone: (310) 277-6910 26 Facsimile: (310) 201-0760 Email: rfeinstein@pszjlaw.com 27 jdulberg@pszjlaw.com 28

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1 ARTICLE XIV 2 CONFIRMATION REQUEST AND RECOMMENDATION 3 14.1 Request for Confirmation. The Plan Proponents jointly request that the Bankruptcy Couconfirm the Plan and that it do so, if applicable, pursuant to section 1129(b) of the Bankruptcy Cod4 notwithstanding the rejection of the Plan by any Impaired Class. 5 14.2 Recommendation for Confirmation. The Plan Proponents believe that confirmation animplementation of the Plan are the best alternative under the circumstances and urge all Impaire 6 Creditors entitled to vote on the Plan to vote in favor of and support Confirmation of the Plan. 7 8 May ___, 2021 9 Brad Smith 10 CRO of Debtors and Debtors in Possession 11 May ________,, 22002211 12 13 ________________________________ AAuutthhoorriizzeedd RReepprreesseennttaattiivvee ooff 14 OOffffiicciiaall CCoommmmiitttteeee ooff UUnnsseeccuurreedd CCrreeddiittoorrss15 Submitted by: 16 Debtors’ Counsel 17 Alan J. Friedman (Bar No. 132580) SHULMAN BASTIAN FRIEDMAN & BUI LLP 18 100Spectrum Center Drive, Suite 600 Irvine, California 92618 19 Telephone: (949) 340-3400 Facsimile: (949) 340-3000 20 Email: afriedman@shulmanbastian.com 21 -and- 22 Committee Counsel 23 Robert J. Feinstein (Pro Hac Vice) Jeffrey W. Dulberg (Bar No. 181200) 24 PACHULSKI STANG ZIEHL & JONES LLP 10100 Santa Monica Blvd., 13th Floor 25 Los Angeles, CA 90067 Telephone: (310) 277-6910 26 Facsimile: (310) 201-0760 Email: rfeinstein@pszjlaw.com 27 jdulberg@pszjlaw.com 28

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1 PROOF OF SERVICE OF DOCUMENT 2 I am over the age of 18 and not a party to this bankruptcy case or adversary proceeding. My business address is 100 Spectrum Center Drive, Suite 600, Irvine, CA 92618. 3 A true and correct copy of the foregoing document entitled (specify): SUBMISSION OF CONFIRMED 4 SECOND AMENDED JOINT CHAPTER 11 PLAN OF LIQUIDATION PROPOSED BY DEBTORS AND OFFICIAL COMMITTEE OF UNSECURED CREDITORS, AS MODIFIED will be served or was served (a) 5 on the judge in chambers in the form and manner required by LBR 5005-2(d); and (b) in the manner statebelow: 6 1. TO BE SERVED BY THE COURT VIA NOTICE OF ELECTRONIC FILING (NEF): Pursuant to 7 controlling General Orders and LBR, the foregoing document will be served by the court via NEF and hyperlink to the document. On (date) July 12, 2021 I checked the CM/ECF docket for this bankruptcy cas8 or adversary proceeding and determined that the following persons are on the Electronic Mail Notice List treceive NEF transmission at the email addresses stated below: 9 10  Service information continued on attached pag 11 2. SERVED BY UNITED STATES MAIL: On (date) , I served the following persons and/or entities at the last known addresses in12 this bankruptcy case or adversary proceeding by placing a true and correct copy thereof in a sealed envelope in the United States mail, first class, postage prepaid, and addressed as follows. Listing the judg13 here constitutes a declaration that mailing to the judge will be completed no later than 24 hours after the document is filed. 14 15  Service information continued on attached pag 16 3. SERVED BY PERSONAL DELIVERY, OVERNIGHT MAIL, FACSIMILE TRANSMISSION OR EMAIL 17 (state method for each person or entity served): Pursuant to F.R.Civ.P. 5 and/or controlling LBR, on (date) , I served the following persons and/or entities by personal delivery, overnight 18 mail service, or (for those who consented in writing to such service method), by facsimile transmission and/or email as follows. Listing the judge here constitutes a declaration that personal delivery on, or 19 overnight mail to, the judge will be completed no later than 24 hours after the document is filed. 20 21  Service information continued on attached pag 22 I declare under penalty of perjury under the laws of the United States that the foregoing is true and correct. 23 24 July 12, 2021 Lori Gauthier /s/ Lori Gauthier Date Printed Name Signature 25 26 27

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1 ADDITIONAL SERVICE INFORMATION (if needed): 2 1. SERVED BY THE COURT VIA NOTICE OF ELECTRONIC FILING (“NEF”) 3 4 • Jonathan T Amitrano jamitrano@taylorlaw.com, ltaylor@taylorlaw.com,ecf@taylorlaw.com • Kyra E Andrassy kandrassy@swelawfirm.com, 5 lgarrett@swelawfirm.com;gcruz@swelawfirm.com;jchung@swelawfirm.com • David M Banker dbanker@lowenstein.com, dbanker@lowenstein.com 6 • Richard L Barnett rick@barnettrubin.com, kelly@barnettrubin.com • James Cornell Behrens jbehrens@milbank.com, 7 gbray@milbank.com;mshinderman@milbank.com;dodonnell@milbank.com;jbrewster@milbank. om;JWeber@milbank.com 8 • Shraddha Bharatia notices@becket-lee.com 9 • Matthew Bouslog MBouslog@gibsondunn.com, jsprecher@gibsondunn.com • J Scott Bovitz bovitz@bovitz-spitzer.com 10 • Larry Butler notices@becket-lee.com • Frank Cadigan frank.cadigan@usdoj.gov 11 • Andrew W Caine acaine@pszjlaw.com • David Cantrell dcantrell@lc-law-llp.com 12 • Jeffrey D Cawdrey jcawdrey@grsm.com, madeyemo@gordonrees.com;sdurazo@grsm.com • Conrad K Chiu cchiu@pryorcashman.com 13 • Shawn M Christianson cmcintire@buchalter.com, schristianson@buchalter.com • Theodore A Cohen tcohen@sheppardmullin.com, amontoya@sheppardmullin.com 14 • Erinn M Contreras econtreras@sheppardmullin.com, nsaucedo@sheppardmullin.com • Joseph Corrigan Bankruptcy2@ironmountain.com 15 • Raphael Cung rcung@callahan-law.com, jeggleston@callahan-law.com;deisenbrey@callahan-law.com;mmartinez@callahan-law.com 16 • J.D. Cuzzolina info@cuzzlaw.com, jp@cuzzlaw.com • Michael T Delaney mdelaney@bakerlaw.com, TBreeden@bakerlaw.com 17 • Jessica DiFrancesco notices@becket-lee.com 18 • Caroline Djang caroline.djang@bbklaw.com, laurie.verstegen@bbklaw.com;wilma.escalante@bbklaw.com 19 • Jeffrey W Dulberg jdulberg@pszjlaw.com • Robert J Feinstein rfeinstein@pszjlaw.com 20 • Scott D Fink colcaecf@weltman.com • Marc C Forsythe kmurphy@goeforlaw.com, mforsythe@goeforlaw.com;goeforecf@gmail.co21 • Alan J Friedman afriedman@shulmanbastian.com, lgauthier@shulmanbastian.com • Matthew T Furton mfurton@lockelord.com, 22 Donna.Mathis@lockelord.com;autodocket@lockelord.com • Thomas M Gaa tgaa@bbslaw.com 23 • Beth Gaschen bgaschen@wgllp.com, kadele@wgllp.com;cbmeeker@gmail.com;cyoshonis@wgllp.com;lbracken@wgllp.com;bgaschen24 @ecf.courtdrive.com • Nancy S Goldenberg nancy.goldenberg@usdoj.gov 25 • David B Golubchik dbg@lnbyb.com, stephanie@lnbyb.com • Christopher J Green chrisgreen@ucla.edu, chrisgreen@ucla.edu;christopher-green-26 2815@ecf.pacerpro.com • Justin D Harris jdh@harrislawfirm.net, felicia@harrislawfirm.net 27 • Michael J Hauser michael.hauser@usdoj.gov • Eric M Heller eric.m.heller@irscounsel.treas.gov

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1 • Joan Huh joan.huh@cdtfa.ca.gov • Lillian Jordan ENOTICES@DONLINRECANO.COM, RMAPA@DONLINRECANO.COM 2 • Samuel M Kidder skidder@ktbslaw.com • Rika Kido rkido@shulmanbastian.com, avernon@shulmanbastian.com 3 • Jeannie Kim jkim@buchalter.com, dgatmen@sheppardmullin.com • Alan M Kindred akindred@leechtishman.com, 4 alankindred@hotmail.com;dtomko@leechtishman.com;challer@leechtishman.com • Armand R. Kizirian armand@kizirianlaw.com, 5 armand@boyamianlaw.com;michael@boyamianlaw.com;narine@boyamianlaw.com • Stuart I Koenig Skoenig@leechtishman.com, 6 sfrey@leechtishman.com;jabrams@leechtishman.com • Alan J Kornfeld akornfeld@pszjlaw.com, mdj@pszjlaw.com 7 • Matthew J Kraus mkraus@lc-lawyers.com, mbuchheit@lc-lawyers.com 8 • Jeffrey C Krause jkrause@gibsondunn.com, dtrujillo@gibsondunn.com;jstern@gibsondunn.com 9 • Donny P Le Donny.Le@doj.ca.gov • Yochun Katie Lee kylee@akingump.com, 10 tsouthwell@akingump.com;westdocketing@akingump.com • Elan S Levey elan.levey@usdoj.gov, tiffany.davenport@usdoj.gov 11 • William N Lobel wlobel@tocounsel.com, jokeefe@tocounsel.com;sschuster@tocounsel.com • Aaron J Malo amalo@sheppardmullin.com, 12 jsummers@sheppardmullin.com;bespinoza@sheppardmullin.com;abilly@sheppardmullin.com • Robert S Marticello Rmarticello@swelawfirm.com, 13 gcruz@swelawfirm.com;lgarrett@swelawfirm.com;jchung@swelawfirm.com • Ashley M McDow amcdow@foley.com, sgaeta@foley.com;smoses@foley.com;ashley-mcdow14 8850@ecf.pacerpro.com • David W. Meadows david@davidwmeadowslaw.com 15 • Reed M Mercado rmercado@sheppardmullin.com • Harlene Miller harlene@harlenemillerlaw.com, harlenejd@gmail.com 16 • Raymond F Moats colcaecf@weltman.com • Elizabeth L Musser elizabeth.musser@clydeco.us 17 • Jeffrey P Nolan jnolan@pszjlaw.com 18 • Courtney E Norton cnorton@greenbergglusker.com, kwoodson@greenbergglusker.com;jking@greenbergglusker.com;calendar@greenbergglusker.co19 • Ryan D O'Dea rodea@shulmanbastian.com, LGauthier@shulmanbastian.com • John M O'Donnell john.o'donnell@ftb.ca.gov, Martha.Gehrig@ftb.ca.gov 20 • Ernie Zachary Park ernie.park@bewleylaw.com • Ronak N Patel rpatel@rivco.org, dresparza@rivco.org;mdominguez@rivco.org 21 • Mary A Petrovic petrovic.mary@pbgc.gov, efile@pbgc.gov • Marc S Pfeuffer pfeuffer.marc@pbgc.gov, efile@pbgc.gov 22 • Kathy Bazoian Phelps kphelps@raineslaw.com, hchoi@raineslaw.com,bclark@raineslaw.com• Christopher E Prince , 23 jmack@lesnickprince.com;cprince@ecf.courtdrive.com;jnavarro@lesnickprince.com • Amelia Puertas-Samara itcdbgc@edd.ca.gov, itcdgc@edd.ca.gov 24 • Christopher B Queally cqueally@callahan-law.com, jluirette@callahan-law.com • Michael B Reynolds mreynolds@swlaw.com, kcollins@swlaw.com 25 • Todd C. Ringstad becky@ringstadlaw.com, arlene@ringstadlaw.com • Christopher O Rivas crivas@reedsmith.com, chris-rivas-8658@ecf.pacerpro.com 26 • Jeremy E Rosenthal jrosenthal@sidley.com • Joel W Ruderman ruderman.joel@pbgc.gov, email@pbgc.gov 27 • Peter J Rudinskas pjr.legal@gmail.com

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1 • James M Sabovich jsabovich@callahan-law.com, ksalour@callahan-law.com;jkirwin@callahan-law.com;rcung@callahan-law.com;bmccormack@callahan-2 law.com;erichards@callahan-law.com;SRobinson@callahan-law.com • Jonathan C Sandler jsandler@bhfs.com, pherron@bhfs.com;sgrisham@bhfs.com 3 • Scott A Schiff sas@soukup-schiff.com • Daren M Schlecter daren@schlecterlaw.com, assistant@schlecterlaw.com 4 • George E Schulman GSchulman@DanningGill.Com, danninggill@gmail.com;gschulman@ecf.inforuptcy.com 5 • Leonard M Shulman lshulman@shulmanbastian.com • Donald W Sieveke , dws4law@pacbell.net 6 • Donald W Sieveke ibmoola@yahoo.com, dws4law@pacbell.net • David A Smyth smythlaw@gmail.com, dsmyth2_@hotmail.com 7 • Alex E Spjute spjute@hugheshubbard.com, gaurav.reddy@hugheshubbard.com 8 • Sarah Stuppi Sarah@stuppilaw.com • Charles Tsai CHARLES.TSAI@DOJ.CA.GOV 9 • Helena Tseregounis helena.tseregounis@lw.com • United States Trustee (SA) ustpregion16.sa.ecf@usdoj.gov 10 • Daniel Uribe duribe@gmail.com • Elissa A Wagner ewagner@pszjlaw.com 11 • Michael A Wallin mwallin@wallinrussell.com • Michael J. Weiland mweiland@wgllp.com, 12 kadele@wgllp.com;vrosales@wgllp.com;cbmeeker@gmail.com;lbracken@wgllp.com • Scott S Weltman colcaecf@weltman.com 13 • Johnny White JWhite@wrslawyers.com, aparisi@wrslawyers.com;eweiman@wrslawyers.com;chamilton@wrslawyers.com 14 • Brandon J Witkow bw@witkowlaw.com, tg@witkowlaw.com • Steven D Zansberg zansbergs@ballardspahr.com, DocketClerk_Denver@ballardspahr.com 15 16 17 18 19 20 21 22 23 24 25 26 27

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