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-28- <br />70. The Meetings Order also provides that: <br />(a) if the Plan is not accepted by the required majority of the Affected Unsecured <br />Creditors Class or the WARN Act Plaintiffs Class; or <br />(b) if the Applicants determine, in their discretion, that the Plan may not be accepted <br />by either of the Affected Unsecured Creditors Class or the WARN Act Plaintiffs <br />Class, or is otherwise unlikely to succeed for any reason whatsoever, <br />then without further order of the Court, the Applicants will be permitted to file an amended and <br />restated plan (the "Alternate Plan ", the terms of which are generally described in the Plan) and <br />to proceed with a meeting of the Secured Noteholders Class for the purpose of considering and <br />voting on the resolution to approve the Alternate Plan, in which case the Applicants and the <br />Monitor will have no obligation to proceed with the Unsecured Creditors Meeting or the WARN <br />Act Plaintiffs Meeting. <br />71. The principal effect of the Alternate Plan is that (a) all assets and property of the <br />Applicants will be transferred to an entity designated by the Secured Noteholders and/or Marret <br />(on behalf of the Secured Noteholders), free and clear of all claims and encumbrances, in <br />exchange for the cancellation of the Secured Notes and a release of all obligations of the Secured <br />Noteholders under the Secured Notes; and (b) all unsecured claims and all WARN Act Claims <br />will remain as unaffected claims against the Applicants and receive no distributions or <br />consideration of any kind. <br />CCAA Plan Releases <br />72. The Plan provides for releases on the Plan Implementation Date in favour of, inter <br />alia, the Applicants, the Directors, the Officers, the Cline Companies, the Monitor, the Monitor's <br />