STROOCK & STROOCK & LAVAN LLP Kristopher M - Portrait-trust ...

Bar Date”). Notice of the Administrative Claims Bar Date was sent to approximately 8,700
known and potential creditors and Beneficiaries. To date, approximately 200 proofs of Claim
(the “Administrative Proofs of Claims”) were filed against the Debtors.
17. The Notice of Effective Date provides that any holder of an
Administrative Claim that fails to file a timely Claim
(Notice of Effective Date at 1-2).
[S]hall be forever barred, stopped and enjoined from
asserting such Administrative Claim (or filing an
Administrative Claim Notice or any other proof of Claim
with respect thereto), and the Liquidating Trust, the Debtors
and the Debtors’ Estates shall be forever discharged from any
and all indebtedness or liability with respect to such
Administrative Claim, and such holder shall not be entitled to
receive any Distribution in the Chapter 11 Cases on account
of such Administrative Claim.
18. By Order dated January 8, 2008 (the “Final Administrative Claims Bar
Date Order”) (Docket No. 684), the Bankruptcy Court established February 19, 2008 at 5:00
P.M. (Prevailing Eastern Time) as the bar date for all creditors whose Claims were entitled to
priority status under Sections 503(b) and 507(a) of the Bankruptcy Code, except for those
holders of Administrative Expense Claims who were previously served with Notice of Effective
Date (the “Final Administrative Claims Bar Date”). Notice of the Final Administrative Claims
Bar Date was sent to approximately 500 parties that may have held Administrative Claims but
may not have received the Notice of Effective Date, and, to date, no additional Administrative
Proofs of Claim have been filed against the Debtors’ Estates.
19. Pursuant to the Pre-Petition Bar Date Order, the Plan and the Confirmation
Order, the Notice of Effective Date and the Final Administrative Claims Bar Date Order, any
person or entity, including all governmental entities, that holds or asserts a Claim against any of
the Debtors was required to submit a Claim on or before the applicable Bar Date.
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