objection letter - 13

7/27/2019 Objection Letter - 13

1/8

1

August 14, 2013Judge Allan L. GropperUnited States Bankruptcy CourtSouthern District of New YorkOne Bowling GreenNew York, NY 10004-1408

Re: Eastman Kodak Case 12-10202 (ALG) Breach of Fiduciary Duties and Violation ofBankruptcy and Security Laws by Blackstone GSO Capital Partners.

Dear Judge Gropper,

I respectfully request the court to deny confirmation of Debtors First Amended Joint Chapter 11 Planof Reorganization (the Plan), because there is sufficient evidence that the Plan has been developed inBad Faith by Blackstone GSO Capital Partners (GSO) collaborating with Debtors, and GSO hasbreached its fiduciary duties and violated bankruptcy and security laws and the bad-faith provisions ofBankruptcy Code Section 1126 (e), and there are reasonable grounds to believe that there has been a

violation of 18 U.S.C. Section 152, which makes it a criminal offence.

1. Backstop Parties have jointly developed the Plan with Debtors and have jointly solicited votes forthe acceptance of the Plan. GSO is the leading partner of Backstop Parties with a 50.6% share.

2. GSO has been a fiduciary of Debtors since the bankruptcy petition date, January 19, 2012. GSOhas been a member of the 2nd Lien Secured Note Holders Committee (2nd Lien Committee) since itsformation in November 2011. In addition, GSO was a lender of Debtors DIP financing, and the lenderof both New Money Loans and Junior Loans.

3. Blackstone (the owner of GSO) has been retained as the financial advisor by the 2nd LienCommittee since November 10, 2011, with the sole responsibility to negotiate with Debtors on behalfof 2nd Lien Committee in order to ensure that the 2 nd Lien Holders dont see their investmentdevalued.

4. As a fiduciary of Debtors, GSO has breached its fiduciary duty and violated bankruptcy and securitylaws by trading Debtors secured notes, unsecured notes and claims on material non-publicinformation for the sole purpose of accumulating a blocking position in secured notes and a controllingposition in one of the two voting unsecured claim classes with some help from its Backstop partners.

5. GSO has acted in bad faith by using its controlling position in secured notes when it negotiated theInitial Plan with Debtors that would have given GSO a 23.7% ownership of New Kodak. Debtorsagreed to give 85% of New Kodaks 40 million shares to the $375M secured note holders to cancelthis debt. Blackstone accumulated $104.4M secured notes before the Initial Plan negotiations to affectthe formulation of the Plan and to obtain potentially huge trading profits.

6. Exhibit 1 shows GSOs trading of Debtors secured and unsecured debt since the petition date, asreported by 2019 Rule filings in the dockets. GSO sold out its $58.5M secured notes position that ithad on January 21, 2012 and then repurchased secured notes and accumulated a $104.4M securednotes position (27.8% of the total $375M secured notes) just before the Initial Plan filed on April 30,2103. It is evident that GSO has accumulated Debtors secured debt in bad faith before it negotiatedthe Initial Plan with Debtors. GSO had non-public material information about Debtors business andbankruptcy emergence plans and strategies while doing these trades. GSO executed these trades, asa judiciary insider, in order to obtain substantial trading profits violating the bankruptcy and securitylaws.

7. Exhibit 2 shows GSOs trading of Debtors unsecured claims. The source of the data is the TransferAgreements filed with the court under the Bankruptcy Rule 2019. GSO reported 33 trades of Debtorsunsecured claims from February 15, 2013 to July 23, 2013.


2/8

2

8. GSOs interest in unsecured claims started after the Citigroups purchase of the RetireesSettlement (OPEB) Claims of $635M for only $70M on January 23, 2013 - 89% lower than the facevalue of the claims. Citigroup is not in the business of speculating in unsecured claims of bankruptcompanies. Citigroup acts as an intermediary and it is very likely that Citigroup already had buyers(Backstop Parties) lined up before it purchased the OPEB claims. In fact, within three weeks of itspurchase, Citigroup sold $532M of the $635M OPEB claims to three of the four hedge funds in the

Backstop partnership - GSO, BlueMountain Capital Management and Contrarian CapitalManagement, as shown in Exhibit 2, 3 and 4. GSO purchased $135M OPEB claims from Citigroup foraround $14M. With these purchases, GSO and its Backstop partners established a controlling positionin the unsecured Settlements Claims class, one of the two voting classes of Debtors unsecuredclaims.

9. The key part of the Plan is the $406M Rights Offering that GSO and its Backstop partnersnegotiated with Debtors. The Rights Offering is structured to give at least a 52.8% ownership of NewKodak to Backstop Parties including GSOs 18.2% share. Basically, if the Plan is approved, GSO willhave purchased 18.2% of New Kodak for around $91M - $14M for purchasing $135M unsecuredclaims and $77M for purchasing 6.4M rights, including 5.1M overallotment rights.

10. Assuming a fair value of $5B for New Kodak, GSOs 18.2% ownership will be worth $910M.Then,

GSO will be making 900% profit on its $91M investment - a great incentive for GSO to breach itsfiduciary duty and violate bankruptcy and security laws.

11. Exhibit 2 shows that GSO reported 28 trades of Debtors unsecured claims after the Plan wasannounced on June 25, 2013. It is evident that not only that GSO acted in bad faith by establishing acontrolling position before jointly formulating the Plan with Debtors, it also acted in bad faith andviolated the fairness of the voting process by entering into special arrangements with selectedunsecured creditors to secure their Yes votes to the Plan.

12. It is evident that in order to get the support of Credit Committee, GSO and its Backstop partnersoffered participation in the lucrative Rights Offering to the other vulture hedge funds and high networth individuals who have bought Debtors unsecured claims at 85% discount like themselves. Thesevulture funds and high net worth individuals, together with Backstop Parties, have accumulated close

to 80% of Kodaks unsecured claims, and are now in a position to make 900% profits, if the Plan isconfirmed. GSO breached its fiduciary duty and violated bankruptcy and security laws by collaboratingwith Credit Committee in formulating a fraudulent reorganization plan which is not in the best interestsof the small unsecured creditors and the equity holders.

13. It is evident that GSO obtained Debtors agreement to the Plan by offering Debtors existingmanagement executive positions in New Kodak with lucrative compensation packages including stockoptions that will have substantial upside due to the intentional low valuation of New Kodaksreorganization value that they negotiated with Debtors. If the Plan is confirmed, Debtors existingmanagement will reap huge financial rewards in return for their support of the Plan. GSO breached itsfiduciary duty and violated bankruptcy and security laws by collaborating with Debtors in formulating afraudulent reorganization plan which is not in the best interests of the small unsecured creditors andthe equity holders.

>>>> Sign here


3/8

3

Exhibit 1 - Blackstone GSO Capital Partners Trading of Debtors Secured and Unsecured Debt

1. Docket 151, 01/31/2012 Reported ownership of $11M secured 2018 notes, $47.5M secured 2019notes and $16.9M unsecured 2017 convertible notes.

2. Docket 769, 04/02/2012 Reported ownership of $2.5M secured 2018 notes; have sold out all ofits $47.5M secured 2019 notes, $16.9M unsecured 2017 convertible notes, and $8.5M of its secured2018 notes.

3. Docket 1715, 07/07/2012 Reported ownership of $50.5M secured 2018 notes, $16.5M secured2019 notes; have bought $48M additional secured 2018 notes and $16.5M new secured 2019 notes.

4. Docket 2389, 11/14/2012 Reported zero economic interest; have sold out all of its $50.5Msecured 2018 notes and $16.5M secured 2019 notes.

5. Docket 3689, 05/07/2013 Reported ownership of $66.3M secured 2018 notes, $38.1M secured2019 notes and $135M unsecured claims. All are new positions.

Exhibit 2 - Blackstone GSO Capital Partners Trading Records of Debtors Unsecured Claims

1. Docket 4412, 07/23/2013 - Transfer Agreement FRBP. REVISED Transfer Agreement 3001 (e) 2

Transferors: Deutsche Bank Securities (Claim No. 6026, Amount \$5, 000, 000.00) To GSO Credit-A

Partners LP (related document(s)[4379]) filed by Raniero DAversa on behalf of GSO Credit-A

Partners LP. (DAversa, Raniero)

2. Docket 4411, 07/23/2013 - Transfer Agreement FRBP. Transfer Agreement 3001 (e) 2 Transferors:

GSO Special Situations Overseas Master Fund Ltd. (Claim No. 6026, Amount \$6, 773, 520.00) To

Deutsche Bank Securities Inc. filed by Jeffrey M. Olinsky on behalf of Deutsche Bank Securities Inc..

(Olinsky, Jeffrey)


Transferors: GSO Special Situations Fund LP (Claim No. 6026, Amount \$8, 809, 206.00) To Seaport

Loan Products LLC (related document(s)[4394]) filed by Raniero DAversa on behalf of GSO Special

Situations Fund LP. (DAversa, Raniero)


Transferors: Seaport Loan Products LLC To GSO Special Situations Fund LP (related document(s)

[4386]) filed by Raniero DAversa on behalf of GSO Special Situations Fund LP. (DAversa, Raniero)


Seaport Loan Products LLC (Claim No. 6026, Amount \$8, 809, 206.00) To GSO Special Situations

Fund LP filed by Raniero DAversa on behalf of GSO Special Situations Fund LP. (DAversa, Raniero)


Seaport Loan Products LLC (Claim No. 6026, Amount \$5, 000, 000.00) To GSO Special Situations

Overseas Master Fund LTD filed by Raniero DAversa on behalf of GSO Special Situations Overseas

Master Fund Ltd.. (DAversa, Raniero)


Seaport Loan Products LLC (Claim No. 6026, Amount \$5, 000, 000.00) To GSO Palmetto

Opportunistic Investment Partners LP filed by Raniero DAversa on behalf of GSO Palmetto

Opportunistic Investment Partners LP. (DAversa, Raniero)


4/8

4


Seaport Loan Products LLC (Claim No. 6026, Amount \$5, 000, 000.00) To GSO Credit-A Partners LP

filed by Raniero DAversa on behalf of GSO Credit-A Partners LP. (DAversa, Raniero)


GSO Special Situations Overseas Master Fund LTD (Claim No. 6026, Amount \$8, 547, 041.00) ToSeaport Loan Products LLC filed by Raniero DAversa on behalf of GSO Special Situations Overseas

Master Fund Ltd.. (DAversa, Raniero)

10. Docket 4388, 07/19/2013 - Transfer Agreement FRBP. Transfer Agreement 3001 (e) 2

Transferors: GSO Palmetto Opportunistic Investment Partners LP (Claim No. 6026, Amount \$6, 172,

504.00) To Seaport Loan Products LLC filed by Raniero DAversa on behalf of GSO Palmetto



Transferors: GSO Credit-A Partners LP (Claim No. 6026, Amount \$6, 471, 249.00) To Seaport Loan

Products LLC filed by Raniero DAversa on behalf of GSO Credit-A Partners LP. (DAversa, Raniero)


Transferors: GSO Special Situations Fund LP (Claim No. 6026, Amount \$5, 000, 000.00) To Seaport

Loan Products LLC filed by Raniero DAversa on behalf of GSO Special Situations Fund LP. (DAversa,

Raniero)


Transferors: Deutsche Bank Securities Inc. (Claim No. 6026, Amount \$5, 000, 000.00) To GSO

Palmetto Opportunistic Investment Partners LP filed by Raniero DAversa on behalf of GSO Palmetto



Transferors: Deutsche Bank Securities Inc. (Claim No. 6026, Amount \$5, 000, 000.00) To GSOSpecial Situations Fund LP filed by Raniero DAversa on behalf of GSO Special Situations Fund LP.

(DAversa, Raniero)



Special Situations Overseas Master Fund Ltd. filed by Raniero DAversa on behalf of GSO Special

Situations Overseas Master Fund Ltd.. (DAversa, Raniero)



Credit-A Partners LP filed by Raniero DAversa on behalf of GSO Credit-A Partners LP. (DAversa,

Raniero)


Transferors: GSO Special Situations Fund LP (Claim No. 6026, Amount \$6, 904, 603.00) To

Deutsche Bank Securities Inc. filed by Jeffrey M. Olinsky on behalf of Deutsche Bank Securities Inc..

(Olinsky, Jeffrey)


Transferors: GSO Palmetto Opportunistic Investment Partners LP (Claim No. 6026, Amount \$5, 586,

252.00) To Deutsche Bank Securities Inc. filed by Jeffrey M. Olinsky on behalf of Deutsche Bank

Securities Inc.. (Olinsky, Jeffrey)

19. Docket 4374, 07/19/2013 - Transfer Agreement FRBP. Transfer Agreement 3001 (e) 2Transferors: GSO Special Situations Overseas Master Fund Ltd. (Claim No. 6026, Amount \$1, 773,


5/8

5

520.00) To Deutsche Bank Securities Inc. filed by Jeffrey M. Olinsky on behalf of Deutsche Bank

Securities Inc.. (Olinsky, Jeffrey)


Transferors: GSO Credit-A Partners LP (Claim No. 6026, Amount \$5, 735, 625.00) To Deutsche Bank

Securities Inc. filed by Jeffrey M. Olinsky on behalf of Deutsche Bank Securities Inc.. (Olinsky, Jeffrey)

21. Docket 4361, 07/18/2013 - Transfer Agreement FRBP. / Notice of Partial Transfer of Claim other

than for Security Pursuant to Rule 3001(e) Transferors: GSO Palmetto Opportunistic Investment

Partners LP (Claim No. 6026, Amount \$5, 000, 000.00) To Citigroup Financial Products Inc. filed by

Douglas R. Davis on behalf of Citigroup Financial Products Inc.. (Davis, Douglas)


than for Security Pursuant to Rule 3001(e) Transfer Agreement 3001 (e) 1 Transferors: GSO Special

Situations Overseas Master Fund LTD. (Claim No. 6026, Amount \$5, 000, 000.00) To Citigroup

Financial Products Inc. filed by Douglas R. Davis on behalf of Citigroup Financial Products Inc..

(Davis, Douglas)


than for Security Pursuant to Rule 3001(e) Transfer Agreement 3001 (e) 1 Transferors: GSO Special

Situations Fund LP (Claim No. 6026, Amount \$5, 000, 000.00) To Citigroup Financial Products Inc.

filed by Douglas R. Davis on behalf of Citigroup Financial Products Inc.. (Davis, Douglas)


than for Security Pursuant to Rule 3001(e) Transferors: GSO Credit-A Partners LP (Claim No. 6026,

Amount \$5, 000, 000.00) To Citigroup Financial Products Inc. filed by Douglas R. Davis on behalf of

Citigroup Financial Products Inc.. (Davis, Douglas)


Transferors: Citigroup Financial Products Inc. (Claim No. 6026, Amount \$8, 679, 909.00) To GSOSpecial Situations Overseas Master Fund LTD. filed by Raniero DAversa on behalf of GSO Special

Situations Overseas Master Fund Ltd.. (DAversa, Raniero)


Transferors: Citigroup Financial Products Inc. (Claim No. 6026, Amount \$8, 665, 131.00) To GSO

Special Situations Fund LP filed by Raniero DAversa on behalf of GSO Special Situations Fund LP.

(DAversa, Raniero)



Palmetto Opportunistic Investment Partners LP filed by Raniero DAversa on behalf of GSO Palmetto




Credit-A Partners LP filed by Raniero DAversa on behalf of GSO Credit-A Partners LP. (DAversa,

Raniero)

29. Docket 3269, 03/06/2013 - Transfer Agreement FRBP Transfer Agreement 3001 (e) 2

Transferors:GSO Credit-A Partners LP(Claim No.6026, Amount 2, 207, 143.00); GSO Palmetto

Opportunistic Investment Partners LP(Claim No.6026, Amount 1, 757, 143.00); GSO Special

Situations Fund LP(Claim No.6026, Amount 5, 731, 100.00); GSO Special Situations Overseas

Master Fund Ltd.(Claim No.6026, Amount 5, 304, 614.00). To JPMorgan Chase Bank, N.A.. filed by

Howard J. Grossman on behalf of JPMORGAN CHASE BANK NA.(Grossman, Howard)


6/8

6


Transferors:Citigroup Financial Products Inc.(Claim No.6026, Amount 16, 400, 000.). To GSO

Palmetto Opportunistic Investment Partners LP. filed by Raniero DAversa on behalf of GSO Palmetto

Opportunistic Investment Partners LP.(DAversa, Raniero)

31. Docket 3111, 02/15/2013 - Transfer Agreement FRBP Transfer Agreement 3001 (e) 2Transferors:Citigroup Financial Products Inc.(Amount 20, 600, 000.).. To GSO Credit-A Partners LP.

filed by Raniero DAversa on behalf of GSO Credit-A Partners LP.(DAversa, Raniero)


Transferors:Citigroup Financial Products Inc.(Claim No.6026, Amount 53, 490, 269.). To GSO Special

Situations Fund LP. filed by Raniero DAversa on behalf of GSO Special Situations Fund LP.(DAversa,

Raniero)


Transferors:Citigroup Financial Products Inc.(Claim No.6026, Amount 49, 509, 731.). To GSO Special

Situations Overseas Master Fund Ltd.. filed by Raniero DAversa on behalf of GSO Special Situations

Overseas Master Fund Ltd..(DAversa, Raniero

Exhibit 3 - BlueMountain Capital ManagementsTrading Records of Debtors Unsecured Claims

1. Docket 3296, 03/12/2013 - Transfer Agreement FRBP Notice of Partial Transfer of Claim Other

Than For Security Pursuant to Rule 3001(e) Transfer Agreement 3001 (e) 2 Transferors:Citigroup

Financial Products Inc.(Claim No.6026, Amount 4, 984, 000.00). To BlueMountain Long/Short Credit

Master Fund L.P.. filed by Scott Cargill on behalf of BlueMountain Long/Short Credit Master Fund L.P..

(Cargill, Scott)



Financial Products Inc.(Claim No.6026, Amount 6, 000, 000.00). To BM Credit Opportunities MasterFund I L.P.. filed by Scott Cargill on behalf of BlueMountain Credit Opportunities Master Fund I L.P..

(Cargill, Scott)



Financial Products Inc.(Claim No.6026, Amount 931, 000.00). To BlueMountain Timberline Ltd.. filed

by Scott Cargill on behalf of BlueMountain Timberline Ltd..(Cargill, Scott)



Financial Products Inc.(Claim No.6026, Amount 1, 908, 000.00). To BlueMountain Long Short

Grasmoor Fund Ltd.. filed by Scott Cargill on behalf of Blue Mountain Long Short Grasmoor FundLtd..(Cargill, Scott)



Financial Products Inc.(Claim No.6026, Amount 1, 114, 000.00). To BlueMountain Kicking Horse Fund

L.P.. filed by Scott Cargill on behalf of BlueMountain Kicking Horse Fund L.P..(Cargill, Scott)

6. Docket 3244, 03/04/2013 - Transfer Agreement FRBP Notice of Transfer of Claim Other Than For

Security Transfer Agreement 3001 (e) 2 Transferors:Citigroup Financial Products Inc.(Claim No.6026,

Amount 10, 000, 000.00). To BlueMountain Timberline Ltd.. filed by Scott Cargill on behalf of

BlueMountain Timberline Ltd..(Cargill, Scott)


7/8

7



Amount 11, 711, 000.00). To BlueMountain Distressed Master Fund L.P., . filed by Scott Cargill on

behalf of BlueMountain Distressed Master Fund L.P..(Cargill, Scott)

8. Docket 2965, 01/28/2013 - Transfer Agreement FRBP Notice of Transfer of Claim Other Than ForSecurity Transfer Agreement 3001 (e) 2 Transferors:Citigroup Financial Products Inc.(Claim No.6026,

Amount 65, 736, 000.00). To BlueMountain Credit Opportunities Master Fund I L.. filed by Scott Cargill

on behalf of BlueMountain Credit Opportunities Master Fund I L.P..(Cargill, Scott)



Amount 9, 960, 000.00). To BlueMountain Strategic Credit Master Fund L.P.. filed by Scott Cargill on

behalf of BlueMountain Strategic Credit Master Fund L.P..(Cargill, Scott)



Amount 5, 884, 000.00). To BM Long/Short Credit & Distressed Reflection Fund. filed by Scott Cargillon behalf of BlueMountain Long/Short Credit and Distressed Reflection Fund, a sub-fund of AAI

BlueMountain Fund PLC.(Cargill, Scott)



Amount 35, 203, 000.00). To BlueMountain Long/Short Credit Master Fund L.P.. filed by Scott Cargill

on behalf of BlueMountain Long/Short Credit Master Fund L.P..(Cargill, Scott)


Transferors:Citigroup Financial Products Inc(Claim No.6026, Amount 8, 361, 000.00). To

BlueMountain Kicking Horse Fund L.P.. filed by Scott Cargill on behalf of BlueMountain Kicking Horse

Fund L.P..(Cargill, Scott)


Transferors:Nokia Corporation(Claim No.1337, Amount 1, 140, 000.00). To BLUEMOUNTAIN

DISTRESSED MASTER FUND, L.P.. filed by Primeshares.(Wilson, Charmaine)


Transferors:Nokia Corporation(Claim No.1337, Amount 564, 000.00). To AAI BLUEMOUNTAIN FUND,

PLC. filed by Primeshares.(Wilson, Charmaine)


Transferors:Nokia Corporation(Claim No.1337, Amount 2, 844, 000.00). To BLUEMOUNTAIN

LONG/SHORT CREDIT MASTER FUND, L.P.. filed by Primeshares.(Wilson, Charmaine)


Transferors:NOKIA CORPORATION(Claim No.1337, Amount 912, 000.00). To BLUEMOUNTAIN

TIMBERLINE LTD. filed by Primeshares.(Wilson, Charmaine)


Transferors:Nokia Corporation(Claim No.1337, Amount 6, 540, 000.00). To BLUEMOUNTAIN CREDIT

ALTERNATIVES MASTER FUND, L.P.. filed by Primeshares.(Wilson, Charmaine)

18. Docket 984, 04/24/2012 - Transfer Agreement FRBP (Partial) Transfer Agreement 3001 (e) 2

Transferors:JPMorgan Chase Bank N.A.(Claim No.911, Amount 1, 010, 360.75). To BlueMountain

Long/Short Credit Master Fund L.P.. filed by Paul Kizel on behalf of BlueMountain Long/Short CreditMaster Fund L.P..(Kizel, Paul)


8/8

8


Transferors:JPMorgan Chase Bank N.A.(Claim No.911, Amount 384, 028.52). To BlueMountain

Timberline Ltd.. filed by Paul Kizel on behalf of BlueMountain Timberline Ltd..(Kizel, Paul)


Transferors:JPMorgan Chase Bank N.A.(Claim No.911, Amount 443, 461.51). To BlueMountainDistressed Master Fund L.P.. filed by Paul Kizel on behalf of BlueMountain Distressed Master Fund

L.P..(Kizel, Paul)


Transferors:JPMorgan Chase Bank, N.A.(Claim No.508, Amount 184, 591.58). To BlueMountain

Long/Short Credit Master Fund L.P.. filed by Paul Kizel on behalf of BlueMountain Long/Short Credit

Master Fund L.P..(Kizel, Paul)


Transferors:JPMorgan Chase Bank, N.A.(Claim No.508, Amount 70, 161.50). To BlueMountain

Timberline Ltd.. filed by Paul Kizel on behalf of BlueMountain Timberline Ltd..(Kizel, Paul)


Transferors:JPMorgan Chase Bank N.A.(Claim No.508, Amount 81, 019.83). To Blue Mountain

Distressed Master Fund L.P.. filed by Paul Kizel on behalf of BlueMountain Distressed Master Fund

L.P..(Kizel, Paul)

Exhibit 4 - Contrarian Capital Managements Trading Records of Debtors Unsecured Claims


Citigroup Financial Products Inc. (Claim No. 6026, Amount \$22, 000, 000.00) To Contrarian Funds,

LLC filed by Alisa Mumola on behalf of Contrarian Funds, LLC. (Mumola, Alisa)

2. Docket 3836, 05/30/2013 - Transfer Agreement FRBP. Transfer Agreement 3001 (e) 2 Transferors:AM&M Planners, Inc. (Claim No. 852, Amount \$23, 040.00) To Contrarian Funds, LLC filed by Alisa

Mumola on behalf of Contrarian Funds, LLC. (Mumola, Alisa)


Transferors:Vistatec Inc.(Claim No. 372). To Contrarian Funds, LLC. filed by Alisa Mumola on behalf

of Contrarian Funds, LLC.(Mumola, Alisa)


Transferors:Wynit Distribution, LLC(Claim No.5472, Amount 370, 000). To Contrarian Funds, LLC.

filed by Alisa Mumola on behalf of Contrarian Funds, LLC.(Mumola, Alisa)

5. Docket 2979, 01/31/2013 - Transfer Agreement FRBP (Partial) Transfer Agreement 3001 (e) 2Transferors:Citigroup Financial Products Inc.(Claim No.6026, Amount 130, 000, 000.00). To

Contrarian Funds, LLC. filed by Alisa Mumola on behalf of Contrarian Funds, LLC.(Mumola, Alisa)

objection letter - 13

Documents