On or about August 12,
2014, the Debtor filed its Fifth Amended Plan and Disclosure Statement in
connection with its prior settlement with RBS. These filings were made
following the hearings held on July 21, at which further amendments were
directed by the Court to address any remaining objections. As a result,
the Court entered an Order on August 13, 2014 approving the Disclosure
Statement and scheduling a Plan Confirmation Hearing for October 2, 2014 at
10am in the Erie Courtroom, with objections due by September 19, 2014.
The Debtor continues to propose 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 claims sequentially. The Debtor also moved for extensions of time to meet its previously filed Amended Statement of Settlement Milestones with RBS, to which RBS consented. Based upon the information available to the Committee, the Debtor has been able and will continue to meet those milestones as extended. The Committee will continue to monitor these milestones to ensure that the unsecured creditor escrow is being funded for future distributions.