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3016-1 Chapter 11 Disclosure Statement

(a)   Unless the court orders otherwise, a disclosure statement shall include, without limitation:

(1)      Narrative. A description of the events causing the chapter 11 filing;

(2)      Assets. A description and estimated value of assets, including the basis for the valuation assigned to the assets;

(3)      Historic Financial Information. Balance sheet as of the date of the disclosure statement, and income and expense statement (or profit and loss statement) covering the longer of (i) the period that the chapter 11 case has been pending or (ii) the one year period ending the month the disclosure statement is filed;

(4)      Feasibility. Income and expense and cash flow projections in reasonable detail and with an explanation of all assumptions on which the projections are based;

(5)     Summary of Plan. A summary of the plan of reorganization, including a description of the classes established in the plan. Incorporation of the plan text is not sufficient for this purpose;

(6)     Liquidation Analysis. An analysis of the estimated return to creditors if the case were converted to a chapter 7 liquidation, including the assumptions on which the proponent bases the estimate;

(7)     Disclosure of Management. Identification of and proposed compensation and benefits for every person who will participate in management of the debtor after confirmation;

(8)     Future Litigation.

(i)       A description of all anticipated litigation or other proceedings to recover from third parties, whether in the bankruptcy court or other forums;

(ii)      An explanation for not pursuing recovery from third parties, if the proponent contends that the debtor possesses valid claims;

(9)      Tax Attributes.  A discussion of the debtor's significant tax attributes and the probable tax consequences of confirmation of the proposed plan of reorganization to the debtor-in-possession, creditors and other parties in interest;

(10)   Special Classifications. The basis for any special plan classifications or treatments of claims or interests; and

(11)   Administrative Expenses. Actual paid and unpaid administrative expenses of the reorganization as of the date of the disclosure statement; and a projection of administrative expenses through confirmation.

(12)   Executory Contracts and Unexpired Leases. A list of executory contracts and unexpired leases; include for each: parties to agreements, arrearages and cure amounts, if appropriate.

(b)   Disclaimers of accuracy or responsibility for information in a disclosure statement shall be considered a failure to provide adequate information concerning the issue disclaimed.

(c)   A disclosure statement shall not refer to schedules or other information in the case record unless the information is reproduced in or attached to the disclosure statement.

(d)   Upon filing the disclosure statement and plan of reorganization, the plan proponent shall serve a copy of the disclosure statement and proposed plan of reorganization on the United States Trustee, counsel for the unsecured creditors' committee (or upon each member of the creditors' committee if the committee is not represented by counsel), counsel for every secured creditor and all parties requesting notice.