On or about June 8, 2014, the Debtor filed its Fourth Amended Plan
and Disclosure Statement in connection with its prior settlement with RBS. A hearing has been scheduled on the Disclosure Statement for
Thursday, July 24 at 9:30am in the Erie Bankruptcy Courtroom, with objections due by July 17.
Essentially the Debtor proposes to pay unsecured creditors
in full after Plan confirmation or in the months thereafter by depositing monthly payments into escrow for the payment of administrative expense claims and unsecured claim sequentially. The Debtor also previously filed an Amended Statement of Settlement Milestones
setting forth the various obligations that the Debtor has under the settlement
with RBS. Based upon the information available to the Committee, the Debtor has been
able to meet those milestones thus far. The Committee will continue to
monitor these milestones to ensure that the unsecured creditor escrow is being funded
for future distributions.
