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-12- <br />CLAIMS PROCEDURE <br />33. On the Filing Date, this Honourable Court issued the Claims Procedure Order that <br />approved a process for the identification and quantification of claims against the Applicants and <br />their present and former directors and officers. <br />34. As further detailed in the Monitor's Second Report, the Monitor received 4 <br />Notices of Dispute of Claim (as defined in the Claims Procedure Order) from Known Creditors, <br />one of which has been subsequently resolved. The Applicants continue to be engaged in <br />discussions with Known Creditors in order to attempt to resolve the remaining disputes. <br />35. The Monitor received a consolidated Proof of Claim with respect to the WARN <br />Act Claims on January 13, 2015. Legal counsel to the Applicants, with the assistance of the <br />Monitor, engaged in discussions with counsel to the WARN Act Plaintiffs. As further detailed in <br />the Third Goldfarb Affidavit, on January 20, 2015, the Applicants reached an agreement with <br />Class Action Counsel on the terms of a settlement to resolve their claim. As more particularly <br />described herein, such terms are reflected in the amendments contained in the Amended and <br />Restated Plan. Accordingly, the WARN Act Claims have been allowed for voting and <br />distribution purposes provided that: <br />a) the WARN Act Claims (including the associated attorneys' fees included <br />therein) shall be deemed to be unsecured and to have no security or priority <br />status; and <br />b) the Amended and Restated Plan is implemented in accordance with its terms. <br />36. The Monitor received 3 Proofs of Claims from Affected Unsecured Creditors <br />against the Applicants on or before the Claims Bar Date. Each of these claims were disallowed <br />