27. Put simply, the proposed settlement substantially increases the likelihood that the Debtors’ general unsecured creditors will receive a meaningful distribution under the Plan.
28. Based on the foregoing, the Debtors believe that the Settlement Agreement is fair and equitable and immensely beneficial to the Debtors’ estates and, further, that it satisfies the applicable Bankruptcy Rule 9019 standards. As a result, the Debtors respectfully request that the Court approve the Settlement Agreement.
29. In accordance with Bankruptcy Rules 2002 and 9019, the Debtors shall serve a copy of this Motion and the Settlement Agreement on: (a) the Office of the United States Trustee for Region One; (b) counsel to LIMAB; (c) all creditors listed on the Debtors’ Schedules, as amended; (d) the Securities and Exchange Commission; (e) the Office of the Attorney General for each of the states where the Debtors operate or operated; (f) the Internal Revenue Service and all other known taxing authorities in the states where the Debtors operate or operated; (g) the United States Department of Justice; (h) counsel to the Committee; and (i) any party which has filed, prior to the date of filing this Motion, a request for service of pleadings in this case.