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-12- <br />32. No Claims Packages were required to be sent to the Secured Noteholders and <br />neither the Secured Noteholders nor the Trustee was required to file Proofs of Claim in respect of <br />Claims pertaining to the Secured Notes. Pursuant to the Claims Procedure Order, the aggregate <br />of all amounts owing directly by Cline in respect of the Secured Notes up to the Filing Date were <br />determined by the Applicants in accordance with the Indentures governing the Secured Notes, <br />with the consent of Marret, and were referenced in the Plan. <br />33. Pursuant to the Claims Procedure Order, the Monitor also provided Claims <br />Packages to the Class Action Counsel (as defined in the Claims Procedure Order) with respect to <br />the WARN Act Class Action (as defined in the Claims Procedure Order). <br />34. Among other things, the Claims Procedure Order established 5:00 p.m. on <br />January 13, 2015 as the Claims Bar Date and seven calendar days after the termination, <br />repudiation or resiliation of an applicable agreement or other event giving rise to a Restructuring <br />Period Claim as the Restructuring Period Claims Bar Date (as defined in the Claims Procedure <br />Order). <br />Review of Status of Claims Procedure for Unsecured Creditors <br />35. The Monitor received 4 Notices of Dispute of Claim (as defined in the Claims <br />Procedure Order) from Known Creditors, one of which has been subsequently resolved. The <br />Applicants will continue to be engaged in discussions with Known Creditors in order to attempt <br />to resolve the remaining disputes. <br />36. The Monitor received a Proof of Claim with respect to the WARN Act Claims on <br />January 13, 2015. The Applicants, with the assistance of the Monitor, continue to be engaged in <br />discussions with the counsel to the WARN Act Plaintiffs in order to resolve their claim. <br />