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connection with. relating to, or arising out of,the Chapter 11 Case, the pursuit of confirmation of the Plan, the consummation
<br /> of the Plan,or the administration of the Plan or the property to be distributed under the Plan. except for their willful
<br /> misconduct or gross negligence,and in all respects shall be entitled to reasonably rely upon the advice of counsel with respect
<br /> to their duties and responsibilities under the Plan.
<br /> Notwithstanding any other provision of this Plan, no holder of a Claim or Interest. no other party in interest, none of their
<br /> respective agents, employees,representatives,financial advisors, attorneys,or affiliates. and no successors or assigns of the
<br /> foregoing, shall have any right of action against the Debtors,the Estate(s),Reorganized SFAC,the Creditors'Committee. the
<br /> Claims Resolution Committee,the Debtors'Representative or any of their respective present or former members,officers,
<br /> directors,employees.advisors, attemeys, or agents, for any act or omission in connection with, relating to, or anstng out of,
<br /> the Chapter 11 Case,the pursuit of confirmation of the Plan,consummation of the Plan,or the administtation of the Plan or
<br /> tl;e property to be distributed under the Plan,except for their willful misconduct or gross negligence.
<br /> D. injunction
<br /> Except as otherwise provided in the Plan, the Confirmation Order shall provide,among other things,that from and after
<br /> the Confirmation Date,all Persons who have held,hold,or may hold Claims against or Interests in the Debtors are
<br /> permanently enjoined from taking any of the following actions against the Debtors,the Reorganized Debtors, the Esuate(s),
<br /> the Disbursing Agent,or any of their property on account of any such Claims or Interests: (i)commencing or continuing, in
<br /> any manner or in any place, any action or other proceeding; (ii)enforcing,attaching,collecting or recovering in any manner
<br /> any judgment,award,decree or order;(iii)creating, perfecting or enforcing any lien or encumbrance;(iy�asserting a setoff,
<br /> right of subrogation or recoupment of any kind against any debt. liability or obligation due to the Debtors;and
<br /> (v)commencing or continuing, in any manner or in any place,any action that does not comply with or is inconsistent with the
<br /> provisions of the Plan;provided, however, that nothing contained herein shall preclude such persons from exercising their
<br /> rights pursuant to and consistent with the terms of this Plan.
<br /> E. Termination Of Subordination Rights; Settlement Of Related Claims And Controversies
<br /> 1. All Debt Securities Claims and all rights and claims between or among their holders, relating in any manner
<br /> whatsoever to claimed subordination rights, "make-whole" rights,rights to postpetition and default interest,or similar rights,
<br /> if any(collectively, "Subordination-Related Rights"), shall be deemed satisfied by the distributions under,described in,
<br /> contemplated by,and/or implemented by this Plan to holders of such Debt Securities Claims and such rights shall be deemed
<br /> waived,released,discharged,and terminated as of the Effective Date,and all actions related to the enforcement of such
<br /> Subordination-Related Rights shall be permanently enjoined. Distributions under,described in,contemplated by, and/or
<br /> implemented by this Plan shall not be subject to levy, garnishment, attachment,or like legal process by any holder of a Claim.
<br /> including, but not limited to,holders of Debt Securities Claims,by reason of any claimed Subordination-Related Rights or
<br /> otherwise, so that each holder of a Claim shall have and receive the benefit of the distributions in the manner set forth and
<br /> described in this Plan.
<br /> 2. Pursuant to Fed.R. Bankr.P.9019 and in consideration for the distributions and other benefits provided under,
<br /> described in,contemplated by,and/or implemented by this Plan,the provisions of this Article XII Section E shall constitute a
<br /> good faith compromise and settlement of all claims or controversies relating to the termination of all contractual,legal and
<br /> equitable Subordination-Related Rights that any holder of a Claim, including,but not limited to,a holder of a Debt Securities
<br /> Claim may have with respect to any such Claim,or any distribution to be made on account of any such Claim. The entry of
<br /> the Confirmation Order shall constitute the Bankruptcy Court's approval of the compromise or settlement of all such claims or
<br /> controversies,including,without limitation,the compromise and settlement embodied in the Plan's treatment of Debt
<br /> Securities Claims as described in Article III Section C,and the Bankruptcy Court's finding that such compromises and
<br /> settlements are fair,equitable, and reasonable,and in the best interests of the Debtors,their Estates,and all Claim holders,
<br /> including affected holders of Debt Securities Claims.
<br /> PLAN-26
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