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,~~,' <br />•~.. <br />7. The Illinois Attorney General has filed a claim in the <br />bankruptcy proceeding of CCDC in the amount of $11,000,000.00. <br />The Metropolitan District asserts claims arising from the <br />Agreement in an undetermined amount. There have been <br />approximately 863 claims filed in the bankruptcy proceeding of <br />~ CCDC, the vast majority of which are claims of present and <br />former lot owners. <br />8. The Trustee has insufficient funds to carry out the <br />"lot swap" program contemplated by the Final Judgment and <br />Consent Decree, or to pay the claims filed in the bankruptcy <br />proceeding of CCDC. <br />9. Since her appointment as Trustee of the debtor <br />entities, the Trustee has attempted to negotiate a settlement <br />involving the disposition of all property owned by debtor <br />CCDC. The Trustee has been unable to reach an agreement which <br />satisfies completely the concerns of the Pueblo County, <br />Colorado Treasurer. <br />10. The Trustee has reached an agreement with the Attorney <br />General of the State of Illinois and the Metropolitan District <br />in full, final and complete satisfaction of their claims. The <br />Trustee believes such agreement to be in the best interests of <br />the estate and its creditors. The terms of the proposed <br />agreement are as follows: <br />JOI2dT MOTION TO AUTHORIZE SALE OF REAL PROPERTY <br />OF THE ESTATE FREE AND CLEAR OF ALL LIENS, CLAIMS <br />:,:iD E.:CU:4E.~::h;:LS A.ai; SETTLEMEidT AGREEMENT - Page 4 <br />