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We the Terrestar Common Equity Shareholders stand together to object and Appeal the Confirmation of TerreStar Corporation Plan

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United States Bankruptcy Court                                                                        

Southern District of New York           

One Bowling Green

New York, NY 10004-1408 

Petition last updated on - January 14, 2013 

Ref: TerreStar Corporation

Case Number: 11-10612

In Re: Lead Case No.


TERRESTAR NETWORK, et al 10 CV 15466 (SHL) 


Dear Honorable Judge Lane,

WE THE TERRESTAR EQUITY SHAREHOLDERS JOINTLY OBJECT TO AND APPEAL THE CONFIRMATION OF TSC DEBTORS' THIRD PLAN OF REORGANIZATION. The above-captioned case Plan of Reorganization (POR) was approved by Honorable Judge Lane on 24th October 2012the hearing for which was held on 10th October 2012 at the United States District Court of the Southern District of New York. See plan approval docket at - 


Pursuant to the applicable provisions of the Bankruptcy Code and Bankruptcy Rule, We TerreStar Corporation equity shareholders, formally appeal and submit our objection to the confirmation of TSC Debtors' Third Plan of Reorganization.

This reorganization planning is not confirmable because it is NOT DONE IN GOOD FAITH and VIOLATES FIDUCIARY DUTIES.

We are requesting an expedited hearing to appeal the ruling of the Bankruptcy Judge, the Honorable Sean H. Lane, on October 10, 2012 regarding the confirmation of the third amended Plan of Reorganization. This is based upon Debtors deceit, deliberate violations of Securities laws, and multiple violations of the Sarbanes-Oxley Act. There was deliberate mis-management and collusion to enrich certain insiders, and self-dealing, with the consent and approval from numerous members of the management, from certain members of the Board of Directors, the Chairman of the Board and the in-house lawyer. These parties disregarded and completely ignored their full obligation and fiduciary responsibilities to the common shareholders in violation of the regulatory requirements of the Sarbanes-Oxley Act. Sarbanes-Oxley absolutely requires a public traded company to abide and respect the shareholders' right for transparency and full accountability of all financial transactions.

Your Honor, we, the common shareholders, have requested the appointment of an Equity Committee and an Independent Examiner numerous times, unfortunately, it was denied every time. We also requested a "STAY", Docket #442, and again, it was denied. Your Honor, we are only asking what is fair and equitable as owners of common shares and the respect of the equity ownership, the same as was granted for Chemtura Corporation, Case # 09-11233 (REG). This case was tried in the same United States Bankruptcy Court of the Southern District of New York. Although, the appointment of an Equity Committee was blocked numerous times by the United States Trustee; nevertheless, the request was granted by Honorable Judge Robert E. Gerber. The result was fair and equitable for Chemtura shareholders. Please refer to the docket link below for more details.



Your Honor, we are being victimized by a very carefully crafted SCAM of bankruptcy crimes and more precisely, by a "Constructive Fraud". We ask Your Honor to examine closely what is being attempted. We ask Your Honor do not let greed overcome the decision of the rule of law and justice. 

We are requesting to overrule the ruling of The Honorable Judge Lane and grant the appointment of an Equity Committee and the appointment of an Independent Examiner, to examine and maximize the real fair value of the estate.


The reasons for appeal are as follows-

1. Without an equity committee and independent examiner-

This chapter 11 plan of reorganization has not been filed in good faith. These Debtor entities know well that the efforts of equity holders, who because of their lack of financial resources, have requested the appointment of an examiner to independently value the debtors' assets, and independently evaluate and assess the Debtor’s affairs and transactions, both pre-bankruptcy and during these bankruptcy proceedings, have been successfully blocked by them.

This is the core issue of this bankruptcy case. An official shareholders’ committee can often extract additional value for the otherwise junior interests of equity. Shareholders were totally ignored in this bankruptcy proceeding. It overlooked that committee representation can provide shareholders with a vehicle to challenge valuation of the bankrupt Debtor, in order to show value for equity at the Debtor’s expense. 

This reorganization plan violates the "VALUE MAXIMIZATION NORM". This corporate bankruptcy proceeding violates the priority of claims, and the priority violation at least prima facie is driven by the quest to maximize firm value.

In this case, no one is present to look after the best interest of the estate, thus the management, counsel and financial advisor violated their fiduciary duties.

Those exercising control rights do not make value-maximizing decisions. 

It fails to appoint an equity committee and independent examiners to maximize its value. This reorganization planning was done in bad faith.

2.  Self-Dealing, Fraudulent Transfer or violation of Section 548-

The 1.6 GHz Spectrum, once owned under the entity of Skyterra by TerreStar Corporation, was sold to the Hedge Fund Harbinger Capital Partners Master Fund I, LTD., and their Hedge Fund Manager Phillip Falcone (In which he has been charged with violations of Securities laws) and taken private. The transaction was estimated at $2 Billion Dollars back in September 12, 2010 by a leading telecommunication analyst. Yet the sale occurred on March 29, 2010 for the remaining 45,147,477 common shares for only $5.00 per share, or for a value of $225,737,385.00, to the Hedge Fund Harbinger.

Yet Your Honor based on the Form 10-Q as of June 30, 2008, TerreStar Corporation made an investment totally of $222 Million to purchased 25.5 Million Skyterra in which the non-voting ownership interest in Skyterra was 27.7% as of June 30, 2008. Well Your Honor if you divide 25.5 Million common shares into $222 Million Dollars that gives a price per share of $8.71 per share. So Your Honor we must question why did TerreStar Corporation management paid $8.71 per share and yet on March 29, 2010 sells the Skyterra common shares to Phillip Falcone for only $5.00 per shares on March 29, 2010. Your Honor that is a loss of $3.71 per share. Why did this occur in the first place?

Based upon disclosure by their Senior Vice-President for Public Relations and Communications at LightSquared (The former name of Skyterra), Terry Neal formerly from "Skyterra" the same identical 1.6 GHz Spectrum that was acquired by the Hedge Fund Harbinger Capital Partners Master Fund I, LTD., and its Hedge Fund Manager Phillip Falcone was valued in the Billions of Dollars . This was dated on November 8, 2011.

Therefore Your Honor we must question and ask why and how it can be valued at least $2 Billion Dollars and TerreStar Corporation sells their interest of the 1.6 GHz Spectrum License for only $225,737,385.00. And yet, TerreStar Corporation files for Chapter 11 Bankruptcy on February 16, 2011. Prior the 2 years of filing the petition for Chapter 11. This is demonstrating clearly Your Honor a complete violation of Section 548 or a “FRAUDULENT TRANSFER ". Please review Docket # 660.


This is also a case of “Self-Dealing".

This is one of the VERY STRONG reasons why an Independent Examiner and an Equity Committee is need who can question these questionable and suspicious transactions in which the common equity holders valuation have been deliberately undervalued by using these particular tactics. 

We are questioning isn’t this inside trading and influence peddling between Phillip Falcone, Gary Epstein and Jeffrey Epstein? We are questioning about the relationship between these three and the former Chief of Staff of the Chairman of the F.C.C., Edward Lazarus. The only way we would able to maintain these proceedings is by means of an investigative and independent panel to questions these matters.

TSC is the majority owner of TSN by 89.3% disclosed countless of times in the Quarterly filing in the 10-Q. Therefore, why was TSN sold separately if TSC was not sold at the same time? Under the charter and the regulatory requirement the sale of TSN is a violation of the S.E.C., mandate. TSN is not a public traded company, but TSC is. The former CEO Jeffrey Epstein, the in-house lawyer Douglas I. Brandon and the Debtor lawyers know very well that they are violating the securities laws by doing so.

In October 2010, TerreStar Network Inc. filed for Chapter 11, Solus and Millennium International Management LP, holders of preferred stock; also have a motion on the Nov. 16 calendar asking the bankruptcy judge to dismiss the Chapter 11 cases of seven TerreStar affiliates. They say the companies don't need reorganization and the value of their businesses should flow to the parent company, TerreStar Corp. 


But Insiders were quietly selling common shares and purchasing notes. Much later, in February 2011 TerreStar Corporation also filed Chapter 11 bankruptcy. Please note, Harbinger sold millions of common shares and used those funds to buy notes before the filing of the bankruptcy. They knew the very same amount of the dollars was worth more in notes than the common shares value. They benefited significantly from the inside information. 

Clearly, TerreStar Networks Inc. and TerreStar Corporation, two separated bankruptcies benefit no one but insiders, corporate executives and lawyers.

Please note, the major preferred share holders and note holders are also insiders. With their new restructure plan, the new company will go to the same insiders and wipe out public Minority Common Share Holder's. Please see Docket #611, section J.


The United States Code TITLE 18 sections are also violated. The violations are –


a). Violation of Section 152 - Concealment of assets, false oaths and claims,

b). Violation of Section 154 - Adverse interest and conduct of officers,

c). Violation of Section 156 - Knowing disregard of bankruptcy law or rule,

d). Violation of Section 157 - Bankruptcy fraud, 

e). Violation of Section 158 - Designation of United States attorneys and agents of the Federal Bureau of Investigation to address abusive reaffirmations of debt and materially fraudulent statements in bankruptcy schedules. 

TerreStar Corporation and TerreStar Networks Inc., must be immediately refer to the S.E.C., and the F.B.I. for violations of securities laws and for criminal acts of bankruptcy laws.

3. Rules Violated-

(a). 11 USC § 1102 - Creditors’ and equity security holders’ committees-

This rule states "On request of a party in interest, the court may order the appointment of additional committees of creditors or of equity security holders if necessary to assure adequate representation of creditors or of equity security holders. The United States trustee shall appoint any such committee."

Your Honor, the equity committee was never appointed for us TerreStar common equity holders.

The rule details are at:



This rule says "For all confirmation hearings the plan proponent must prepare a written ballot summary in substantially the same form as Appendix L-3018-b. In addition to indicating how each class and each claimant voted, the original summary shall also have each original ballot attached. At the confirmation hearing the original ballot summary and one copy will be submitted to the Court for filing. The plan proponent shall make available upon request a copy of the ballot summary three (3) calendar days prior to the confirmation hearing to any party objecting to the confirmation of the plan and to the proponent of any competing plan and its counsel.


Your Honor this was never done!

Violation of Rule 3018 (b) conflicts with section 1125 A and B, section 1126 A and B, section USC 548, and failure to comply with Governmental statues under Federal laws and regulations.

The rule details are at:




The rule details are at:


4. Improper valuation proceedings - Undervaluation of FCC licensed 1.4 GHz spectrum –

Asset valuations were inflated and deflated at varies time to favor their circumstances, misled investors and caused financial suffering (please see Docket #670). The Debtors have repeatedly argued that the infrastructure for the 1.4 Spectrum is immature and that it is not developed. However, there are numerous exhibits submitted that prove otherwise. 

(a).  PLUM Consulting valuation of 1.4 GHz Spectrum – 

A study was done by the Plum Consulting, a very respected telecommunication consultants based in London, England. According to Plum, the 1.4 GHz Spectrum is a very valuable asset for the European telecommunication market and perhaps Northern African region as well. The 1.4 GHz Spectrum is worth multiple Billion of Dollars in Europe.


(b). Jefferies & Company valuation of 1.4 GHz Spectrum – 

On February 2008 TSC files PRE 14C, in which the 1.4 GHz spectrum is exercised for 30 million common shares going to Echostar. Investment Banker Jefferies & Company does the fairness opinion that valued the spectrum at $533.4 million, $640 million and $856.2 million, or $0.23, $0.29 and $0.37 MHz POP. (See docket 402, page 8, 23)




(c). RKF Engineering report on TerreStar’ s 1.4 GHz valuation – 

RKF Engineering, one of the respected experts in Spectrum field stated that 1.4 GHz Band is a and very efficient spectrum can be used for LTE PICO CELL and mobile applications providing coverage to as high as 87% (or many millions of customers) of total US population (See Table 8 of the RKF market study report). The RKF market study on 1.4 GHz can be found at – 


The Pico sites can be easily integrated with the already available Macro cells to increase network efficiency. With exponential increase in broadband data service demand due to increase in smartphones over past 2-3 years these Pico cell sites definitely brings a lot of value to the table which was not considered for evaluations by the debtors. The Debtors removed or concealed the True and Fair value of these cell sites. They denied this in a Federal Bankruptcy Court under Oath.

Referring to Page 21 of 94 of the RKF report and quoting the evaluator - “Based on FCC regulations in Table 4, it would be more efficient to operate bands A and B as a single 3-MHz channel instead of separate channels.  This will require an FCC waiver.  However, we see no reason why the FCC would not grant this waiver and consider it low risk.  The rest of this report assumes that this waiver will be granted.” 

“The 3-MHz paired spectrum (1392-1395 and 1432-1435 MHz) can be operated in frequency division duplex (FDD) mode with the BS transmitting in half of the band and the MT transmitting in the other half of the band, as in a cellular deployment. The FCC regulations do not constraint which part of the band to be downlink (BS transmit) and which to be uplink (MT transmit). Therefore, we can pick the solution that provides the best sharing configuration. However, due to the low max EIRP level (100 Watt or 20 dBW) for Fixed Stations in 1392-1395 MHz, this band cannot be used for macro-cell Base Station downlinks (which require EIRP levels on the order of 27 dBW); instead, it is more suitable for smaller cell areas such as pico-cells. Furthermore, we found that it didnot make a significant difference in terms of adjacent band sharing if the lower or upper part of the band was used for downlink or uplink.”

These particular cells can and will be multiplied over the next 5 years by atleast 200-500% because of the low cost to produce these Pico cells.

As per the RKF report, 1.4 GHz spectrum can be used for Machine-to-Machine (M2M) solutions and for LTE network extension through the use of Pico/Femto cells. The addition of the 1432-1435 MHz band to M2M applications would be of significant value and would allow the operators to incorporate high power BS. According to a new report from Analyst Mason, the M2M device connections worldwide will grow by a factor of 20 in the next ten years, from 100.4 million to 2.1 billion, and the penetration of M2M connections as a percentage of overall population in developed markets will grow from 5% in 2011 to 86% by 2021. Refer to the link below for reference – 


Please refer to the Amendments & References section below for more information on 1.4 GHz evaluation.

(d). Marathon Asset Management valuation of TSC and TSN spectrum assets – 

Marathon believes that TerreStar's spectrum (both its 1.4 GHz spectrum and its 2.0 GHz S-Band spectrum) are substantially undervalued by the Debtors, and that at a proper estimate, as high as in the range of $0.50/MHZ-POPs, or $4.3 Billion Dollars, would produce a valuation of TSC's common stock in the range of $2.7 Billion. And such a common stock valuation does not even take into account the value of other assets such as the two satellites (TS-1 and TS-2) with TSC and it subsidiaries. EchoStar understands this "upside" potential, which is why it has been so quick to convert its major holdings in the Debtor's first -priority notes secured by the spectrum-over $500 Million in face value. See Docket #129, Item #9, Page 6 at - 


(e). Undervaluation of 1.4 GHz Spectrum by Managing Director of BlackStone Group Mr. Steven Zelin – 

Mr. Steven Zelin, who specialized in Accounting, Restructuring and Reorganization, not an expert in the field of Spectrum valuation, is a Financial Advisor from the BlackStone Group who testified under oath for the Debtor TSC. According to Mr. Steven Zelin, the 1.4 GHz Spectrum “Fairness Opinion” valuation that was published in February 2008 by Jefferies & Company was over-inflated, thus, those numbers cannot be trusted. The BlackStone Group valued the 1.4 GHz Spectrum in the range of $160 Million to $235 Million Dollars.

Two years after the November 9, 2010, release of the spectrum asset valuation declaration from the legal counsel representing Marathon Asset Management, Inc, Mr. Steven Zelin from The BlackStone Group, claims that the 1.4 GHz Spectrum is worth only in the range of $160 Million Dollars to $235 Million Dollars. This valuation from Mr. Steven Zelin is more than TEN times less than what was evaluated by Marathon Asset Management and approximately FOUR times less than Jeffery's and Company valuation. Due to the spectrum crunch and FCC statements (see section (f) below - speech by FCC chairman Julius Genaschowski on October 4, 2012) the value of spectrum has increased significantly after 2008. The public investors have been grossly misled. And Your Honor, Judge Sean H. Lane was deliberately misled also.

(f).   Quote by The Federal Communication Commission Chairman Julius Genaschowski on October 4, 2012, at Wharton School, University of Pennslyvania-

Quoting a few points from the following February 2012 article-

"The problem, known as the "spectrum crunch," threatens to increase the number of dropped calls, slow down data speeds and raise customers' prices. It will also whittle down the nation's number of wireless carriers and create a deeper financial divide between those companies that have capacity and those that don't."

"U.S. still has a slight spectrum surplus. But at the current growth rate, the surplus turns into a deficit as early as next year, according to the Federal Communications Commission's estimates.". More details in the following CNN Money article-


(g). Interest of Japan’s Softbank to acquire Clearwire/Sprint Spectrum – 

Currently the sparked interest of Softbank to the Clearwire/Sprint Spectrum, cannot ignore the proper Spectrum valuation. As of Oct 12, 2012 Japan’s third largest mobile carrier, Softbank, is in talks to acquire 70% of Sprint, the third largest mobile carrier in the US. It appears to be a land-grab. Or more accurately, a spectrum grab. Please refer to the following link for complete article – 


(h). TSN 2.0 GHz and the 1.4 GHz band in TSC, are intangible assets of widely recognized but disputed value.

TerreStar’s financial advisors have grossly understated the spectrum values. For example, DBSD, a congruent company, with virtually identical spectrum to TSN’s, was also sought and recently purchased by Echostar out of bankruptcy. Early in the bankruptcy proceedings of both DBSD and TSN, Echostar attempted to take each company with DIP financing facilities of $87.5 (DBSD) and $75 (TSN) million. Judge Gerber’s court, which has been administrating the DBSD bankruptcy, and this court, wisely rejected these transparent efforts by an insider of both companies to buy each company from itself, as controlling owners, at a price its hand-chosen management had set. The net result is that Echostar bought both companies in court-sponsored auctions from themselves and the creditors, for a combined value of $2.775 billion. ICO, the majority shareholder of DBSD, received approximately $300 million in the buyout from Echostar. The current TSC plan discloses that the common shareholders will not receive a distribution.

TerreStar Networks Inc. is the largest division of TerreStar Corporation. The valuable asset of TerreStar Networks Inc. is the primary reason the majority of the investors invested in TerreStar Corporation. In a separated bankruptcy, the TerreStar Networks Inc. was sold to EchoStar Corporation, Charles Ergen, for a total amount of $1,375,000,000; $391 Million Dollars for the 2.0 GHz Spectrum License alone, and $984 Million Dollars for both satellites TS-1 (Currently in space since July 1, 2009) and TS-2. Asset valuations were inflated and deflated at varies time to favor their circumstances. This is a clear case of stealing and bending rules to benefit a selective few.

Although, estimating an asset’s fair value is challenging in the current depressed environment, nevertheless –

i). Can you replace assets of the TerreStar Network, satellites, TS-1, TS-2, and the Spectrum 2.0 for 1.375 billion? 

ii). Can you replace all debtors’ assets at the value that is given in this reorganization plan?  

iii). Is this valuation proceeding just, equitable and fair to share holders?

Although strategic bankruptcy is not a criminal act, concealment of assets, concealment or destruction of documents, conflicts of interest, fraudulent claims, fraudulent transfers, false statements, declarations, or redistribution arrangements are Bankruptcy fraud, a white-collar crime. Please refer to the following website-


5.  New Value-

Elektrobit Corp. of Finland filed a lawsuit against the parent company of mobile satellite services startup TerreStar Networks, which was under Chapter 11 bankruptcy protection. On August, 2012, Elektrobit received payment of 13.5 million USD from TerreStar Corporation in full and final satisfaction of its claim against TerreStar Corporation. Refer to the Reuters report – 



Will Echo Star, the new owner of the TerreStar Network, repay all loans and claims to its parent company TerreStar Corporation?


6.  Debtors are proposing –

(a). The release of certain causes of action of the TSC Debtors and their estates and the release of certain causes of action by certain holders of Claims and Equity Interests. See docket #650, D, item 82.


(b). The release and discharge of the Released Parties (the “Third-Party Releases”) from all claims that holders of Claims or Equity Interests would have been entitled to assert individually or collectively, except for claims or liabilities arising out of gross negligence, fraud or willful misconduct (the “Third-Party Releases”). See docket #650, D, item 83.


The fact that the Debtors are proposing broad, general and open releases to their officers, directors and insiders, presumably at the behest of these parties, causes serious concerns regarding the necessary impartiality and conflict-interest free requirement of the Debtor entities and the fiduciaries proposing confirmation of the Third Amended Plan.

7. Notwithstanding the fact that the Debtor entities and the proponents of the third Amended Plan know that a complete and thorough investigation has not been undertaken, these entities and the proponents of the Third Amended Plan, in bad faith, seek to obtain a release in favor of the officers, directors and insiders of the Debtor entities (who may have caused the demise of the Debtors' entities through breaches of fiduciary duty, insider transactions, and other misdeeds) for any "known or unknown, foreseen or unforeseen" claims, obligations and causes of action.

8. The proposal for releases of this nature, given the specific circumstances of this case, is in bad faith.

9. The proposed releases are not supported by consideration and more fundamentally, if approved, the releases would forever foreclose any discovery or civil investigation of the actions, omissions, or culpability of the parties and other interested persons at the helm of the Debtors' entities.

10. The acceptance of the proposed releases would, therefore, subvert the paramount purpose of the Bankruptcy Code which is to provide bankruptcy and reorganization relief only to honest debtors proposing their plans in good faith.

11. Because the lack of impartiality of the Debtor entities and the proponents of the Third Amended Plan is revealed by the open-ended releases that are being proposed, the necessity of the appointment of an independent examiner or independent consultant should be revisited.


Pre-Bankruptcy and through out this reorganization proceeding, shareholders not only did not received fair, equal representation, information requests by Mr. Jeffrey M. Swarts and Mr. Aldo Ismael Perez were denied over and over based on attorney-client privilege and work-product doctrine.

Where the attorney-client privilege is established, it is not absolute. It may yield to the fiduciary exception to that privilege. The fiduciary exception bars a fiduciary from asserting the attorney-client privilege against those to whom fiduciary duties are owed. The policy obligates fiduciaries to disclose all relevant information to beneficiaries, shareholders, and others to whom duties are owed. In certain circumstances, the attorney-client privilege must yield to the fiduciary exception.

The Debtors' counsel objected to Mr. Swarts requests, based on confidential documents or documents subject to attorney-client privilege or work-product protection. It violated THE FIDUCIARY EXCEPTION.

Again, we would like to point out that, "The protection of the privilege" extends only to communications and not to facts.


Debtors' counsels, officers and directors, financial advisors, ignore that they are paid by the estate and they are not looking after the best interests of the estate and maximizing its value, in violation of fiduciary duty and the fiduciary exception.  For one of the example, please see docket #640.


13. PROTESTING any further compensation to Debtor's financial advisor and Law Firm- 

We the common shareholders vigorously PROTEST AND REJECT any further compensation to the financial advisor "The BlackStone Group" especially to Steven Zelin. His testimony regarding the valuation of the 1.4 GHz Spectrum in which he downplayed its true and the enormous valuation especially with the possibility of this spectrum to be used for PICO CELL deployments and applications. Mr. Zelin's unwillingness to even address or discuss this is questionable.

We also VIGOROUSLY PROTEST AND REJECT any further compensation to the Debtor law firm, AKIN GUMP STRAUSS HAUER & FELD, LLP, for using bad faith practices along with the members of the Board of Directors, in-house lawyer Douglas Brandon, for their refusal in seeking the very best interests for the minority common equity holders and for lack of their fiduciary responsibilities and obligation under the Sarbanes-Oxley Act. 

We are Protesting and Rejecting any further compensation. We are demanding that the above compensations be returned to the treasury of TerreStar Corporation. We also demand that the Office of The United States Trustee should appoint a different and fair United States Trustee on the behalf of the minority common equity holders.

We continue to demand the accountability and a thorough investigation from the United States Regulatory and Enforcement Agencies.

For all the reasons we have listed above-


 2. We are requesting to overrule the ruling of The Honorable Judge Lane and grant the appointment of an Equity Committee and the appointment of an Independent Examiner, to examine and maximize the real fair value of the estate.


(a). The release of certain causes of action of the TSC Debtors and their estates and the release of certain causes of action by certain holders of Claims and Equity Interests . See docket #650, D, item 82.


(b). The release and discharge of the Released Parties (the “Third-Party Releases”) from all claims that holders of Claims or Equity Interests would have been entitled to assert individually or collectively, except for claims or liabilities arising out of gross negligence, fraud or willful misconduct (the “Third-Party Releases”). See docket #650, D, item 83.


4. WE REQUEST THE COURT CONSIDER "Carved Out", "Sharing a Piece of The Bankruptcy Pie", "New Value", "Gift Doctrine" etc. to enable common share holders to participate the Reorganization planning, without violating the absolute priority rule nor will delaying the reorganization process.

As an extension to this petition please see attached "Petition Amendments & References" section.


Mminority common equity holders


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