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

following the Final Distribution or in the Wind-Up Reserve after the Liquidating Trustee has
performed all of its responsibilities under the Plan, provided, however, that the Liquidating
Trustee is not required to make de minimis Distributions (the “Supplemental Distribution”).
(Plan § 5.7(d)(ii)).
68. For purposes of economy, clarity and expediency, the Liquidating Trustee
requests that the Court approve a $50,000.00 threshold with respect to the Supplemental
Distribution provision of the Plan. Specifically, the Liquidating Trustee seeks approval to make
a Supplemental Distribution if and only if the Liquidating Trust has $50,000.00 or more in Cash
remaining in the Wind-Up Reserve. If, however, the amount of Cash remaining in the Wind-Up
Reserve is in the amount of $50,000.00 or less, then the Trust requests this Court to grant the
Trust the permission to make a contribution to a charity selected by the Liquidating Trustee in
the amount remaining in the Wind-Up Reserve.
V. Authorization to Destroy Documents and Abandon Certain Property
69. The Liquidating Trustee also respectfully requests that the Court grant
relief pursuant to Section 554 of the Bankruptcy Code, Bankruptcy Rule 6007 and the
Liquidating Trust Agreement, to authorize the Liquidating Trustee to abandon, destroy or
otherwise dispose of the Debtors’ documents and any other miscellaneous remaining property
(the “Records and Remaining Property”) free and clean of any liens, Claims and encumbrances
without further Order of this Court.
70. Pursuant to Section 3.2(xiii) of the Liquidating Trust Agreement, the
Liquidating Trustee has the authority to “[a]rrange for the storage and destruction of records . . .
for a minimum period of six months after the Effective Date.” (Liquidating Trust Agreement §
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