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951E. Accordingly, Colonnade’s wholly or partially unperfected security interest in theEmission Credits is avoidable pursuant to section 544 of the Bankruptcy Code, and Plaintiff isentitled to recover from Colonnade and/or Barclays the Emission Credits or the value of theEmission Credits plus interest.COUNT 28B(Recovery of Emission Credits for the Benefit of the Estates)951F. The allegations of paragraphs 1 through 951E of this Complaint are incorporatedherein by reference.951G. Colonnade’s wholly or partially unperfected security interest in the Emission Creditsis avoidable pursuant to section 544 of the Bankruptcy Code, and accordingly, pursuant tosection 550 of the Bankruptcy Code, Plaintiff may recover from the initial transferee or beneficiary,or from any immediate or mediate transferee, the property transferred, or the value of such property,for the benefit of Plaintiff’s estate.COUNT 28C(Transfer of Lien to the Estate)951H. The allegations of paragraphs 1 through 951G of this Complaint are incorporatedherein by reference.951I. For the reasons alleged in Count 73 of this Complaint, to the extent that Barclays isdetermined to have a lien on property of the Subordination Plaintiff’s estate, the Court should enteran order transferring such lien to the Subordination Plaintiff’s estate, pursuant to sections 510(c)(2)and 105(a) of the Bankruptcy Code.COUNT 29(Disallowance of Claims Under Bankruptcy Code Section 502(d))952. The allegations of paragraphs 1 through 951I of this Complaint are incorporatedherein by reference.604041v1/007457-352-