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-23- <br />(h) Employee Priority Claims; and <br />(i) Government Priority Claims. <br />60. The Plan provides that, at the election of the Applicants, the Applicants may <br />satisfy any Unaffected Secured Claims by returning the property of the Applicants that is secured <br />as collateral for such Claim, in which case such Claim shall be deemed to be fully satisfied, <br />provided that if the applicable Unaffected Secured Creditor asserts that there is a deficiency in <br />the value of the collateral relative to the value of the applicable Unaffected Secured Claim, such <br />Creditor shall be permitted to file such unsecured deficiency Claim as a Restructuring Period <br />Claim, which shall be treated as an Affected Unsecured Claim. As of the date of this Second <br />Report, the Monitor has not been advised of any such election by the Applicants. <br />61. As of the date of this Second Report, the Applicants have not advised the Monitor <br />of any Unaffected Secured Claims, other than the Prior Ranking Secured Claims set out in <br />Schedule "A" to the Initial Order. Additionally, the Monitor is advised by the Applicants that <br />Unaffected Trade Creditors are being paid in the ordinary course and that there are no <br />Unaffected Trade Claims to date. <br />62. In addition, the Plan provides that any Person having an Insured Claim shall be <br />limited to recovery in respect of such Insured Claim solely from the proceeds of the applicable <br />Insurance Policies, and Persons with an Insured Claim shall have no right to, and shall not, make <br />any claim or seek any recoveries in respect thereof from the Applicants, the Cline Companies, <br />any Director or Officer or any other Released Party (other than enforcing such Person's rights to <br />be paid by the applicable insurer(s) from the proceeds of the applicable Insurance Policies). <br />