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ARTICLE VI. RESOLVING DISPUTED, CONTINGENT, AND UNLIQUIDATED CLAIMS A. Claims Objection Deadline; Prosecution of Objections Any Debtor, before the effective Date, and the Disbursing Agent, after the Effective Date and until the Claims Objection Deadline, may file an objection to any Cla.rrt,except that the Claims Objection Deadline shall not apply to objections to Claims filed or amended after the Bar Date. B. Distribution Reserve; Estimation of Claims - On the Effective Date,the Disbursing Agent shall establish a reserve(the "Distribution Reserve"). The Distribution Reserve shall initially include art amount sufficient to pay all projected Claims that,either because they have not become due or because they are Disputed Claims,are not payable on the Effective Date,and all projected expenses and compensation of the Disbursing Agent. The Disbursing Agent shall withhold the Distribution Reserve from the Cash or other property to be distributed under the Plan. As to any Disputed Claim, upon a request for estimation by the Debtors,the Court shall determine what amount is sufficient to withhold in the Distribution Reserve on account of such Disputed Claim. The Debtors may request estimation for every Disputed Claim that is unliquidated and the Disbursing Agent shall withhold the Distribution Reserve based upon the estimated amount of such Claim as set forth in a Final Order. The estimated arUount of any Disputed Claim so determined by the Bankruptcy Court will constitute the maximum recovery that the holder thereof may recover after the ultimate liquidation of its Disputed Claim. If the Debtor elects not to request such an estimation from the Court with respect to a Disputed Claim that is liquidated, the Disbursing Agent shall withhold the Distribution Reserve based upon the Face Amount of such Claim. The Debtors anticipate that the Distribution Reserve shall not exceed$20,910,000. In the event the Disbursing Agent wishes to hold more than such amount in the Distribution Reserve, the Disbursing Agent shall first obtain the consent of the Creditors'Committee, if still in existence,or the Claims Resolution Committee before increasing the Distribution Reserve. After any Disputed Claim becomes an Allowed Claim,the Disbursing Agent shall,on the next Periodic Distribution Date, pay to the holder thereof the amount of its Claim as Allowed (or,if less,the amount thereof estimated in accordance with the immediately preceding subparagraph). The Disbursing Agent may,in its sole discretion,make other adjustments as it determines appropriate in the amount held in the Distribution Reserve,and shall distribute, in accordance with this Plan's provisions,all amounts that become available for distribution as a result of the allowance or disallowance of Disputed Claims. If practicable, the Disbursing Agent shall invest any Cash that is withheld in the Distribution Reserve in a manner that shall yield a reasonable net return, taking into account the safety of the investment. C. Claims Resolution After the Effective Date,the Disbursing Agent may settle, without Bankruptcy Court approval (except as set forth below), any Disputed Claim or Estate Claim in accordance with the procedure set forth in this Section C: 1. Claims Resolution Committee The Claims Resolution Committee shall consist of one or two representatives of the holders of the 13-1/4%Subordinated Notes. 2. Debtors'Representative The Disbursing Agent shall retain at least one employee or representative of the Debtors with sufficient knowledge to assist in the resolution of Disputed Claims(the"Debtors'Representative"),for a period of no less than one year after the Effective Date. PLAN-21