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Case 16-42529 Doc 28 Filed 04/13/16 Entered 04/13/16 11:32:40 Main Document <br />Pg 26 of 31 <br />Reservation of Rights <br />50. Nothing contained herein or in the proposed Interim Order and Final Order is <br />intended or should be construed as: (a) an admission as to the validity or priority of any claim <br />against the Debtors; (b) a waiver of the Debtors' or any party in interest's rights to dispute any <br />claim on any grounds; (c) a promise to pay any claim; (d) an implication or admission that any <br />particular claim against the Debtors is an Essential Supplier Claim or a 20 -Day Administrative <br />Claim; or (e) a request to assume or reject any executory contract or unexpired lease pursuant to <br />section 365 of the Bankruptcy Code. The Debtors expressly reserve the right to contest any <br />Essential Supplier Claim or 20 -Day Administrative Claim under applicable bankruptcy and non- <br />bankruptcy law. <br />Notice <br />51. Notice of this Motion has been given to: (a) Davis Polk & Wardwell LLP and <br />Bryan Cave LLP as counsel to Citibank, N.A. as Administrative Agent for the First Lien Secured <br />Credit Facility and the Debtors' proposed debtor in possession secured credit facility; (b) Brown <br />Rudnick LLP, as counsel to Wilmington Savings Fund Society, FSB as prospective trustee and <br />collateral agent for the Secured Second Lien Notes; (c) Foley & Lardner LLP, as counsel to <br />Wilmington Trust Company as prospective Indenture Trustee for the Unsecured Notes;' (d) <br />Robinson & Cole LLP, as counsel to U.S. Bank as resigning trustee and collateral agent for the <br />Second Lien Notes, the Unsecured Notes and the Convertible Notes;' (e) counsel to any ad hoc <br />committees; (f) the Debtors' 50 largest unsecured creditors; (g) Mayer Brown LLP, as counsel to <br />These include the: (i) 6.00% Senior Notes due November 2018; (ii) 6.50% Senior Notes due <br />September 2020; (iii) 6.25% Senior Notes due September 2021; and the (iv) 7.875% Senior Notes due <br />November 2026. <br />These include the: (i) 6.00% Senior Notes due November 2018; (ii) 6.50% Senior Notes due <br />September 2020; (iii) 6.25% Senior Notes due September 2021; (iv) 7.875% Senior Notes due <br />November 2026; and the (v) Convertible Junior Subordinated Debentures due December 2066. <br />-26- <br />