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-21- <br />68. The Chair declared that the requisite majority required by the Meetings Order and <br />section 6 of the CCAA had been obtained for the Secured Noteholders Class and the Secured <br />Noteholders Class Plan Resolution was approved by the Secured Noteholders Class. <br />69. The Secured Noteholders Class Meeting was terminated at approximately 11:25 <br />a.m. <br />SUMMARY OF KEY TERMS IN THE AMENDED AND RESTATED PLAN <br />70. As described in the Second Report, the Monitor received a Proof of Claim with <br />respect to the WARN Act Claims on January 13, 2015. The aggregate value of this Proof of <br />Claim was $4.2 million and, since the date of the Second Report, being January 14, 2015, the <br />Applicants, with the assistance of their legal counsel, the Monitor and Marret, have engaged in <br />discussions with counsel to the WARN Act Plaintiffs ( "WARN Class Counsel ") in order to <br />resolve this claim. <br />71. WARN Class Counsel had previously advised that the WARN Act Plaintiffs <br />would not vote in favour of the Plan without enhanced recovery. Discussions between counsel to <br />the Applicants and WARN Class Counsel, with the input from Marret and the Monitor, have led <br />to the development a proposed resolution (the "WARN Act Resolution ") of the WARN Act <br />Claim by way of amendments to the Plan contained in the Amended and Restated Plan. These <br />key amendments include the following: <br />a) the WARN Act Claims will be fully and forever compromised, released and <br />discharged in respect of the Applicants in exchange for a $90,000 cash payment <br />(the "WARN Payment") to be made on the Plan Implementation Date and an <br />unsecured, non - interest bearing entitlement to receive $120,000 in cash on the <br />