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-29- <br />Counsel, the Trustee, Marret and the Secured Noteholders (collectively and together with other <br />parties receiving releases pursuant to the Plan, the "Released Parties "). <br />73. The Plan provides that the Released Parties shall be released and discharged from <br />any and all claims based in whole or in part on any act, omission, transaction, duty, <br />responsibility, indebtedness, liability, obligation, dealing or other occurrence existing or taking <br />place on or prior to the later of the Plan Implementation Date and the date on which actions are <br />taken to implement the Plan, that constitute or are in any way relating to, arising out of or in <br />connection with any Claims, any Director /Officer Claims and any indemnification obligations <br />with respect thereto, the Secured Notes and related guarantees, the Secured Note Indentures, the <br />Secured Note Obligations, the Equity Interests, the Stock Option Plans, the New Cline Common <br />Shares, the New Secured Debt, the New Credit Agreement, the Unsecured Plan Entitlement, the <br />WARN Act Plan Entitlement, any payments to Convenience Creditors, the business and affairs <br />of the Applicants, the administration and/or management of the Applicants, the Recapitalization, <br />the Plan, the CCAA Proceeding, the Chapter 15 Proceeding or any document, instrument, matter <br />or transaction involving any of the Applicants or the Cline Companies taking place in connection <br />with the Recapitalization or the Plan (referred to collectively as the "Released Claims "), and all <br />Released Claims shall be fully, finally, irrevocably and forever waived, discharged, released, <br />cancelled and barred as against the Released Parties, all to the fullest extent permitted by <br />Applicable Law, provided that nothing in the Plan will waive, discharge, release, cancel or bar: <br />(a) the right to enforce the Applicants' obligations under the Plan; <br />(b) the Applicants from or in respect of any Unaffected Claim or any Claim that is <br />not permitted to be released pursuant to section 19(2) of the CCAA; or <br />