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-15- <br />the Claims Procedure Order) against the Applicants (collectively the "Secured <br />Noteholders Allowed Unsecured Claim "). <br />43. The Applicants and Marret have agreed to set the Secured Noteholders Allowed <br />Unsecured Claim at $17,500,000 and the Secured Noteholders Allowed Secured Claim at <br />$92,673,897 to reflect the deficiency in the overall value of the Cline Group relative to the <br />amounts owed in respect of the Secured Notes. The Claims Procedure Order does not require the <br />Monitor to determine the value of the Secured Noteholders Allowed Secured Claim or the <br />Secured Noteholders Allowed Unsecured Claim. Accordingly, the Monitor has not been <br />involved in the determination of the Secured Noteholders Allowed Secured Claim or the Secured <br />Noteholders Allowed Unsecured Claim. <br />OVERVIEW OF THE PLAN <br />44. The Plan is the result of extensive discussions between the Applicants, Marret and <br />their respective financial and legal advisors. Cline and Marret have entered into a support <br />agreement, pursuant to which Marret (on behalf of the Secured Noteholders) has agreed to <br />support the Recapitalization and the Plan. The Applicants kept the Monitor apprised of the Plan <br />during its development. <br />Summary of the Plan <br />45. This Honourable Court granted the Meetings Order on December 3, 2014, which <br />accepted the Plan for filing and authorized the Applicant to convene the Meetings. <br />46. One of the Applicants' stated purposes of the Plan is to facilitate a <br />recapitalization with a view to maximizing value for the benefit of the Applicants' stakeholders. <br />The Plan contemplates, among other things: <br />